Power purchase disallowance upheld, tax credit needs verification, and interest under sections 234B and 234C remains leviable.

Disallowance of power purchase price payable was upheld because the Tribunal followed its later view in the assessee's own case, noting that the relevant facts and the Nair Committee recommendation were not fully considered in the earlier year. Credit for advance tax and self-assessment tax was allowed only after verification, with the Assessing Officer directed to examine the tax deposits and grant permissible credit. Interest under sections 234B and 234C was sustained, as the Tribunal applied the Supreme Court's interpretation of assessed tax and treated both levies as chargeable.

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Issues: (i) Whether the disallowance of expenditure on account of power purchase price payable was sustainable; (ii) whether credit of advance tax and self-assessment tax required verification and allowance; (iii) whether interest under sections 234B and 234C was chargeable.

Issue (i): Whether the disallowance of expenditure on account of power purchase price payable was sustainable.

Analysis: The Tribunal followed its later orders in the assessee's own case and held that the subsequent view had considered the relevant facts, including the recommendation of the Nair Committee, which had not been fully taken into account in the earlier year. The earlier decision for the prior assessment year was therefore not followed.

Conclusion: The disallowance was upheld and the issue was decided against the assessee and in favour of the Revenue.

Issue (ii): Whether credit of advance tax and self-assessment tax required verification and allowance.

Analysis: The Tribunal accepted that the entitlement to credit depended upon verification of the tax deposits and the tax payable, and that the Assessing Officer should examine the vouchers and grant the permissible credit.

Conclusion: The issue was restored to the Assessing Officer for verification and appropriate credit, in favour of the assessee to that extent.

Issue (iii): Whether interest under sections 234B and 234C was chargeable.

Analysis: Relying on the Supreme Court's ruling on the meaning of assessed tax and the applicability of the same principle to section 234C, the Tribunal held that interest under both provisions was leviable.

Conclusion: The levy of interest under sections 234B and 234C was sustained and the issue was decided against the assessee.

Final Conclusion: The appeal succeeded only in part, with one issue sent back for verification while the remaining substantive additions and interest were upheld.

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