https://www.taxtmi.com/caselaws?id=784691 For benchmarking specified domestic transactions of inter-unit transfer of power for deduction under s. 80-IA, the ITAT held that where electricity is generated for captive consumption, an internal CUP based on the tariff at which the assessee purchases power from the distribution licensee is the appropriate comparator, and the TPO's external CUP was rightly rejected; consequently, no downward ALP adjustment was warranted. The ITAT further held that the power-consuming unit could validly be treated as the tested party, and the TPO's selection of the power-generating unit as the tested party was unsustainable; consequently, the CIT(A)'s order was upheld and the Revenue's appeal was dismissed. en-us Mon, 24 Nov 2025 00:00:00 +0530 Sat, 10 Jan 2026 08:25:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784691 For benchmarking specified domestic transactions of inter-unit transfer of power for deduction under s. 80-IA, the ITAT held that where electricity is generated for captive consumption, an internal CUP based on the tariff at which the assessee purchases power from the distribution licensee is the appropriate comparator, and the TPO's external CUP was rightly rejected; consequently, no downward ALP adjustment was warranted. The ITAT further held that the power-consuming unit could validly be treated as the tested party, and the TPO's selection of the power-generating unit as the tested party was unsustainable; consequently, the CIT(A)'s order was upheld and the Revenue's appeal was dismissed. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784691