Tax determination against deceased proprietor invalid where no notice to legal representative; appeal rejected without addressing jurisdictional defec...
Revocation of GST registration and permission to file blocked returns; conditional defreezing of bank accounts after security and instalment applicati...
Right to access seized electronic evidence: impugned adjudication treated as additional show cause notice, remand for fresh hearing and return of mate...
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The note addresses taxation and deduction treatment of income from sale of Renewable Energy Certificates (RECs). It applies strict statutory construction to deny concessional tax treatment available only for transfers of 'carbon credits' as expressly defined (UNFCCC-validated one tonne CO2 equivalent reductions); RECs, being one MWh renewable generation certificates issued under electricity law, do not meet that definition, so concessional treatment does not apply. Separately, the deduction framework for profits "derived from" power generation requires a direct, first degree nexus with electricity generation; REC receipts are tradable environmental attributes and lack that primary nexus, so they do not qualify for the generation deduction.
The note addresses taxation and deduction treatment of income from sale of Renewable Energy Certificates (RECs). It applies strict statutory construction to deny concessional tax treatment available only for transfers of 'carbon credits' as expressly defined (UNFCCC-validated one tonne CO2 equivalent reductions); RECs, being one MWh renewable generation certificates issued under electricity law, do not meet that definition, so concessional treatment does not apply. Separately, the deduction framework for profits "derived from" power generation requires a direct, first degree nexus with electricity generation; REC receipts are tradable environmental attributes and lack that primary nexus, so they do not qualify for the generation deduction.
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