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Dy. Cit, Central Circle-2(2), Nagpur vs Gopani Iron And Power(India) Pvt. Ltd., ... on 27 March, 2026 cites

Dy. C.I.T.1(2), Raipur vs M/S Rashmi Sponge Iron & Power Pvt. Ltd, ... on 8 August, 2018

The TPO (Transfer Pricing Officer) rejected the CUP method adopted by the assessee and applied the rate at which MSEDCL purchases power from independent generators at the rate of Rs. 3.79/- per unit and consequently proposed a downward adjustment of Rs. 28.22 Crore. The rate applied by the TPO does not reflect market realities or commercial comparables as required under law, for the reasons, viz; (i) the TPO rejected the assessee's benchmarking based on MSEDCL's industrial sale tariff on the basis that it reflects a distribution price and not appropriate for a power 5 ITA Nos. 138 to 141/NAG/2025 (AYs. 2017-18, 18-19, 20-21 & 21-22) Dy. CIT vs. Gopani Iron and Power (India) Pvt. Ltd.
Income Tax Appellate Tribunal - Raipur Cites 0 - Cited by 0 - Full Document

Grasim Industries Ltd.(As A Successor ... vs Dcit- Cc -1(4), Mumbai on 18 October, 2022

electricity supplied by the Electricity Board to industrial consumers and not the rate at which power is procured from generating companies. The Ld. AR further submits that recently in Aditya Birla Nuvo Ltd. v. DCIT in ITA No. 563/Mum/2018 dated 18.09.2025,third Member Bench (Special Bench) wherein the similar issue was raised by the department. The Special Bench after considering the submission of rival parties and held that price at which assessee (industrial consumer) purchased power from State Distribution Company (GUVNL in that case) can be applied as a valid CUP for determining the arm's length price for sale/supply of power by the Captive Power Plant (CPP) to its other industrial units.
Income Tax Appellate Tribunal - Mumbai Cites 11 - Cited by 2 - Full Document

Commissioner Of Income Tax (Large Tax ... vs M/S Reliance Industries Ltd on 2 January, 2019

9. The Hon'ble Bombay High Court in CIT Vs Reliance Industries Limited also (supra) held that where assessee had set up a captive power generating unit and provided electricity to its another unit and claimed deduction under section 80-IA in respect of profits arising out of such activity, valuation of electricity provided to another unit should be at rate at which electricity distribution companies were allowed to supply electricity to consumers.
Supreme Court - Daily Orders Cites 3 - Cited by 143 - Full Document

Deputy Commissioner Of Income Tax vs M/S R.R. Energy Ltd. 60 Taxc/6/2019 ... on 25 June, 2019

ii. Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is correct in relying on the decision of Hon'ble Supreme Court in the case of CIT v. Jindal Steel and Power Limited (C. A. No. 13771 of 2015), when the case of the assessee pertains to AY 2017-18 and therefore the judgments of the Hon'ble Supreme Court for years prior to the introduction of Section 80A(6) vide Finance Act, 2009 and the amendments in Section 80A(6) and sec 80-1A(8) vide Finance Act, 2012 are not applicable to the facts of the assessee. iii.
Chattisgarh High Court Cites 1 - Cited by 119 - Full Document

Shah Alloys Limited,, Ahmedabad vs The Dcit, Cicle-4(1)(1), Ahmedabad on 21 June, 2023

The reliance placed by ld. AR for assessee in case of PCIT vs DCM Shriram, PCIT vs Star Paper Mills Ltd, PCIT vs Gujarat Alkalies & Alkalies & Chemicals Ltd., Shah Alloys Ltd. Vs DCIT, CIT vs Kanoria Chemicals & Industries Ltd. and PCIT vs Rungta Mines Ltd. are misplaced as facts of said cases are clearly distinguishable from the facts and legal framework governing the present appeal. None of these judgments dealt with benchmarking of SDT under arm's length price under section 92BA and 92C read with Rule 10B.
Income Tax Appellate Tribunal - Ahmedabad Cites 20 - Cited by 0 - Full Document

The Pr. Commissioner Of Income Tax ... vs Jindal Steel And Power Ltd. Through Its ... on 4 October, 2021

3. Before CIT(A), the assessee furnished detailed written submission on the issue raised in the appeal. The Ld. CIT(A) after considering the material available before him adjudicating the matter on its merit and by placing reliance on the judgment of Hon'ble Supreme Court in CIT (A) v. Jindal Steel & Power Limited (supra) wherein it was held that for the purpose of determining market value under Section 80-IA of the Act, the appropriate benchmark is the rate at which 6 ITA Nos. 138 to 141/NAG/2025 (AYs.
Supreme Court - Daily Orders Cites 1 - Cited by 2 - Full Document
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