Internal comparable pricing for captive power transfers prevails where same-unit market purchases provide the most reliable arm's-length benchmark.

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....Internal comparable pricing for captive power transfers was accepted where the same consuming units bought electricity from State distribution companies in the same market and period, resulting in deletion of transfer-pricing adjustments. Exempt-income disallowance was confined to dividend-yielding investments, and MAT adjustments required an independent determination of expenditure from the accounts. Expansion-related operating costs remained revenue expenditure unless directly attributable to acquiring or installing capital assets. Captive rail systems qualified as infrastructure facilities for section 80-IA, while common costs required expenditure-based allocation supported by a nexus. Incentives linked to capital investment and expansio.........