Assessee is engaged in business of manufacturing and sale of inorganic chemicals, fertilizers and bio fuels and claimed deduction under section 80-IA. It had also entered into Specified Domestic Transaction (SDT) with its Associated Enterprises (AEs) with respect to sale of electricity from its Power Plant unit to its manufacturing unit-It had benchmarked same by comparing same with rate (6.90 per unit) charged by Gujarat Electricity Board (GEB) and claimed that transaction was at ALP. TPO, however, adopted power procurement rate of GEB at Rs. 3.94 per unit as determined by Gujarat Electricity Regulatory Commission (GERC) and made TP adjustment. Tribunal held that price on which eligible unit was selling power, i.e., at Rs. 6.90 per unit was price available in open market and also same manufacturing unit was purchasing it from GEB at same price.Since per unit electricity sold to non-eligible unit at Rs. 6.90 per unit was market value, assessee was justified in adopting ALP of electricity supply to its AEs at rate charged by GEB. (AY. 2017-18)