ITAT explains Transfer Pricing Method in case of Sale of Electricity to AEs

ACIT Vs Electrosteel Casting Ltd. (ITAT Kolkata) It is clear from the rival contentions that determination price at which Power generated can be sold is subject to statutory control under the provisions of Section 61 & 62 of the Electricity Act, 2003. The Hon’ble Calcutta High Court in its decision rendered in the case of ITC Ltd. has specifically observed that in the case before it electricity generated by the assessee could not be sold to anyone other than a distribution company or a company which is engaged both in generation and distribution. No arguments were advanced before the...