https://www.taxtmi.com/caselaws?id=794054 ITAT Mumbai considered transfer pricing and section 80-IA computation issues. On intra-group loan interest, it accepted a fixed 6.5% benchmark with credit for interest already offered, treating a LIBOR-based floating rate as unsuitable on the facts. On section 80-IA, it held that losses of other eligible units had to be set off against the profits of the profitable unit for deduction computation, so the assessee's unit-wise claim failed. On captive power sales to associated enterprises, it accepted the distribution company's selling rate as a valid comparable for arm's length price, deleting the transfer pricing adjustment. en-us Wed, 18 Mar 2026 00:00:00 +0530 Mon, 29 Jun 2026 09:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794054 ITAT Mumbai considered transfer pricing and section 80-IA computation issues. On intra-group loan interest, it accepted a fixed 6.5% benchmark with credit for interest already offered, treating a LIBOR-based floating rate as unsuitable on the facts. On section 80-IA, it held that losses of other eligible units had to be set off against the profits of the profitable unit for deduction computation, so the assessee's unit-wise claim failed. On captive power sales to associated enterprises, it accepted the distribution company's selling rate as a valid comparable for arm's length price, deleting the transfer pricing adjustment. Case-Laws Income Tax Wed, 18 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794054