Internal CUP Most Appropriate for ALP in Captive Power Plant Transaction: Calcutta HC

PCIT Central- 1 Vs Rungta Mines Limited (Calcutta High Court) Calcutta High Court held that internal Comparable Uncontrolled Price [CUP] is most appropriate method in determining Arm’s Length Price [ALP] for sale of power by Captive Power Plant to non-eligible units of the assessee. Accordingly, appeal of revenue dismissed. Facts- The respondent assessee is engaged in iron ore and manganese ore mining having mines in Orissa and Jharkhand and they also produce sponge iron, billets and power. In these appeals the issue which falls for consideration is the correctness of the addition on the Tra...