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    <title>2025 (5) TMI 747 - ITAT DELHI</title>
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    <description>Amounts retained under regulatory tariff mechanisms for consumer benefit were treated as not constituting the assessee&#039;s real income, so the consumer&#039;s share of efficiency gain from AT&amp;C loss reduction was not taxable. Outstanding energy tax collected from consumers and payable to the municipal authority only on collection was held outside section 43B, as it was not a primary liability of the assessee. Interest on consumer security deposits was allowed as business expenditure because it arose from a statutory obligation under the electricity law. UPS qualified as part of the computer system and attracted higher depreciation. Additions linked to the eligible business were also held to enhance profits for section 80IA deduction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=770475</link>
      <description>Amounts retained under regulatory tariff mechanisms for consumer benefit were treated as not constituting the assessee&#039;s real income, so the consumer&#039;s share of efficiency gain from AT&amp;C loss reduction was not taxable. Outstanding energy tax collected from consumers and payable to the municipal authority only on collection was held outside section 43B, as it was not a primary liability of the assessee. Interest on consumer security deposits was allowed as business expenditure because it arose from a statutory obligation under the electricity law. UPS qualified as part of the computer system and attracted higher depreciation. Additions linked to the eligible business were also held to enhance profits for section 80IA deduction.</description>
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