Power Transfer Pricing u/s 80IA: High Court Validates CUP Method Using State Electricity Board Rates as ALP Benchmark.

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....HC held that Comparable Uncontrolled Price (CUP) method was appropriate for determining Arm's Length Price (ALP) for power transfer between eligible and non-eligible units u/s 80IA. The court affirmed that Rs. 4.39 per kWh, being the rate at which assessee supplied excess power to UPPCL, constituted a valid internal uncontrolled transaction and was correctly accepted as ALP. Following precedent from Jindal Steel case, HC confirmed that State Electricity Board rates for industrial consumers represent market value u/s 80IA(8). The regulated nature of electricity market necessitates comparable transactions to be materially similar without price-affecting differences. Matter resolved in assessee's favor, validating their ALP computation methodology and transfer pricing adjustments.....