https://www.taxtmi.com/caselaws?id=800390 Arm's length pricing of electricity transferred from eligible captive power plants to a non-eligible cement unit for profit-linked tax deduction must use the tariff actually paid by that unit to the distribution licensee. Market value for a specified domestic transaction is the arm's length price applicable in uncontrolled conditions. Regulated supplies by independent generators to State distribution utilities are not reliable comparable uncontrolled price transactions. The cement unit's own purchase from the licensee is a reliable internal uncontrolled comparable, and supplier differences do not defeat comparability. A mark-up cannot be added under the comparable uncontrolled price method; the transfer-pricing adjustment is deleted and the deduction is allowable. en-us Fri, 18 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800390 Arm's length pricing of electricity transferred from eligible captive power plants to a non-eligible cement unit for profit-linked tax deduction must use the tariff actually paid by that unit to the distribution licensee. Market value for a specified domestic transaction is the arm's length price applicable in uncontrolled conditions. Regulated supplies by independent generators to State distribution utilities are not reliable comparable uncontrolled price transactions. The cement unit's own purchase from the licensee is a reliable internal uncontrolled comparable, and supplier differences do not defeat comparability. A mark-up cannot be added under the comparable uncontrolled price method; the transfer-pricing adjustment is deleted and the deduction is allowable. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800390