https://www.taxtmi.com/caselaws?id=444800 ITAT Raipur upheld CIT(Appeals) decision on three issues. First, subsidy received by assessee was correctly characterized as capital receipt, not revenue receipt, following tribunal's own precedent. Second, deduction under section 80IA for power generation unit was properly allowed despite electricity sales to outside parties and captive consumption, supported by HC precedent establishing market rate determination. Third, disallowance under section 14A was invalid as AO failed to record satisfaction regarding assessee's claim that no expenditure was incurred for earning exempt income, with 2022 amendment having prospective application only. en-us Mon, 16 Oct 2023 00:00:00 +0530 Sat, 21 Oct 2023 10:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444800 ITAT Raipur upheld CIT(Appeals) decision on three issues. First, subsidy received by assessee was correctly characterized as capital receipt, not revenue receipt, following tribunal's own precedent. Second, deduction under section 80IA for power generation unit was properly allowed despite electricity sales to outside parties and captive consumption, supported by HC precedent establishing market rate determination. Third, disallowance under section 14A was invalid as AO failed to record satisfaction regarding assessee's claim that no expenditure was incurred for earning exempt income, with 2022 amendment having prospective application only. Case-Laws Income Tax Mon, 16 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444800