No Downward Adjustment Under 80IA Because CPP Transfer Valued Using SEB Consumer Tariff

Aditya BirlaNuvo Ltd. Vs DCIT (ITAT Mumbai) ITAT Mumbai Follows Third Member Majority & Holds SEB Purchase Rate as Valid Internal CUP; 80IA Deduction Allowed Without Downward Adjustment These cross-appeals concerned only one surviving dispute-Ground No 7  relating to determination of market value / ALP for captive transfer of electricity by the assessee’s Captive Power Plant (CPP) to its Rayon manufacturing unit for computing deduction u/s 80IA. Earlier, the Accountant Member (AM) & Judicial Member (JM) delivered differing views, triggering a reference to the Hon’ble Third Member ...