The assessee benchmarked the transfer of electricity generated by its captive power unit to its manufacturing unit by adopting the Comparable Uncontrolled Price (CUP) method based on the tariff charged by the Punjab State Power Corporation Ltd. The Transfer Pricing Officer substituted the Indian Energy Exchange trading rate as the benchmark. The Tribunal held that where a direct internal CUP was available, the electricity tariff charged by the State Electricity Board represented the appropriate market value. In the absence of any justification for adopting the IEX trading rate, the assessee’s transfer price was held to be at arm’s length and the transfer pricing adjustment was deleted. (AY. 2013-14).