https://www.taxtmi.com/caselaws?id=789408 Inter-unit transfer of electricity from a captive power plant is a specified domestic transaction to be valued under the market value concept in section 80-IA(8) read with transfer pricing principles. The accepted benchmark is the tariff at which the distribution company supplies electricity to industrial consumers, not the price at which it procures power from generators. Electricity is treated as a standardised commodity for this comparison, and functional differences between generation and distribution do not defeat comparability. The assessee's consumer-tariff benchmark was therefore upheld and the revenue's adjustment was rejected as unsustainable. en-us Fri, 27 Mar 2026 00:00:00 +0530 Thu, 02 Apr 2026 11:52:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789408 Inter-unit transfer of electricity from a captive power plant is a specified domestic transaction to be valued under the market value concept in section 80-IA(8) read with transfer pricing principles. The accepted benchmark is the tariff at which the distribution company supplies electricity to industrial consumers, not the price at which it procures power from generators. Electricity is treated as a standardised commodity for this comparison, and functional differences between generation and distribution do not defeat comparability. The assessee's consumer-tariff benchmark was therefore upheld and the revenue's adjustment was rejected as unsustainable. Case-Laws Income Tax Fri, 27 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789408