‘Market rate’ for inter divisional notional transfer price cannot be based on rate determined by the Regulator

‘Market rate’ for the purpose of inter divisional notional transfer price cannot be based on the rate determined by the Regulator Facts • Taxpayer is a company engaged in the business of generation and distribution of electricity. • Originally the taxpayer was only in the business of distribution of electricity. Subsequently, in the assessment year 1996-97, the taxpayer had put up a plant for generation of electricity at Dahanu. • The taxpayer had claimed deduction under section 80-IA of the Income Tax Act,1961 (the Act) in respect of income from generation and distribution of electr...