Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
Limitation for final assessment under sections 144C and 153 treated jointly, resulting in quashing of timebarred assessment order and liberty to reviv...
Fixed capacity charges received under a power purchase agreement were held to be profits "derived from" the business of generation and supply of electricity, since the undertaking's sole business was power generation and the charges were inextricably linked to assured capacity allocation; mismatch with actual offtake could not justify restricting deduction to variable charges alone. Deduction under section 80IA was therefore allowable on the entire eligible business receipts, including annual fixed charges. Invocation of section 80IA(10) alleging a colourable device was rejected because the specified domestic transactions were found at arm's length, and the arrangement reflected industry and regulatory pricing norms; the Revenue's appeal was dismissed. - ITAT
Fixed capacity charges received under a power purchase agreement were held to be profits "derived from" the business of generation and supply of electricity, since the undertaking's sole business was power generation and the charges were inextricably linked to assured capacity allocation; mismatch with actual offtake could not justify restricting deduction to variable charges alone. Deduction under section 80IA was therefore allowable on the entire eligible business receipts, including annual fixed charges. Invocation of section 80IA(10) alleging a colourable device was rejected because the specified domestic transactions were found at arm's length, and the arrangement reflected industry and regulatory pricing norms; the Revenue's appeal was dismissed. - ITAT
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