Captive Power Valuation for Section 80IA

In a recurring dispute on captive power valuation, the Tribunal held that benchmarking based on State Electricity Board (SEB) consumer tariffs reflects true market value for Section 80-IA deduction. 

The transfer pricing adjustment made by adopting lower regulatory tariffs applicable to sale of power to utilities was rejected. The ruling reinforces consistency with prior years and underscores that valuation must reflect the consumer-side replacement cost, not the generator-side realization.