https://www.taxtmi.com/caselaws?id=465839 The dominant issue was the correct benchmark for computing deduction under s. 80-IA on profits from captive power generation where electricity is transferred to other units of the same taxpayer and a TP adjustment was made. Relying on its earlier order in the taxpayer's own case and HC precedent, the Tribunal held that, for captive consumption, the arm's length/value for inter-unit transfer should be the tariff charged by electricity distribution companies to end consumers, not the lower rate at which generators sell to distribution companies. Consequently, the DRP's confirmation of a downward TP adjustment was set aside and the AO was directed to delete the addition; the appeal was allowed. en-us Wed, 31 May 2023 00:00:00 +0530 Fri, 09 Jan 2026 13:15:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465839 The dominant issue was the correct benchmark for computing deduction under s. 80-IA on profits from captive power generation where electricity is transferred to other units of the same taxpayer and a TP adjustment was made. Relying on its earlier order in the taxpayer's own case and HC precedent, the Tribunal held that, for captive consumption, the arm's length/value for inter-unit transfer should be the tariff charged by electricity distribution companies to end consumers, not the lower rate at which generators sell to distribution companies. Consequently, the DRP's confirmation of a downward TP adjustment was set aside and the AO was directed to delete the addition; the appeal was allowed. Case-Laws Income Tax Wed, 31 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465839