Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Method

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....Captive power transfers are benchmarked using the tariff charged by State Electricity Boards to industrial consumers, rather than rates charged by generating companies to distribution entities; the consumer tariff reflects market value and arm's length price under the applicable provisions. Transfers of steam by eligible units may qualify for deduction where supported by consistent prior treatment. Common expenses may be allocated to eligible units only where they directly relate to those units, with specified expenses allocated on a manpower basis rather than turnover, requiring recomputation. For effluent treatment plants, an authentic third-party quotation may be used under the Other Method without requiring multiple quotations; the related adjustment is therefore not sustainable. The appeal was partly allowed.....