Transfer pricing adjustment - Determination of arm's length price for power transferred by assessee's...

Transfer pricing adjustment - Determination of arm's length price for power transferred by assessee's captive power plant to non-eligible manufacturing units, reducing deduction claimed u/s 80IA. Market value of power supplied by captive power plants to industrial units should be computed based on rate charged by State Electricity Board for supplying electricity to industrial consumers, as per Supreme Court decision in Rungta Mines Ltd. The rate at which generating units sell power to distribution companies cannot be considered market value, as it does not represent uncontrolled market conditions. The Tribunal correctly computed market value by comparing with rate charged by State Electricity Board to industrial consumers. Appeal of revenue dismissed in favor of assessee. .....

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