https://www.taxtmi.com/caselaws?id=792001 For section 80-IA valuation, electricity generated by a captive power plant and used by eligible manufacturing units is to be benchmarked at the price an industrial consumer would pay in the open market, not at the lower regulated rate for surplus sale to the electricity board. The transfer pricing adjustment on this basis was rejected. On allocation of common head office expenses, a consistently accepted apportionment by fixed assets could not be replaced with a profitability-based ratio without a material change in facts or law. The further allocation made by the Assessing Officer was therefore disallowed, and the relief granted by the first appellate authority was upheld on both issues. en-us Mon, 18 May 2026 00:00:00 +0530 Thu, 21 May 2026 08:30:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792001 For section 80-IA valuation, electricity generated by a captive power plant and used by eligible manufacturing units is to be benchmarked at the price an industrial consumer would pay in the open market, not at the lower regulated rate for surplus sale to the electricity board. The transfer pricing adjustment on this basis was rejected. On allocation of common head office expenses, a consistently accepted apportionment by fixed assets could not be replaced with a profitability-based ratio without a material change in facts or law. The further allocation made by the Assessing Officer was therefore disallowed, and the relief granted by the first appellate authority was upheld on both issues. Case-Laws Income Tax Mon, 18 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792001