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    <title>2024 (7) TMI 1682 - ITAT CHENNAI</title>
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    <description>Industrial promotion assistance linked to setting up a new unit was treated as capital receipt because subsidy character depends on the scheme&#039;s purpose, not the mode of quantification, and was therefore not taxable as revenue income. Railway siding expenditure and the feeder-line enhancement component of power transmission were treated as revenue items subject to verification, while sub-station conversion and commissioning costs were capital in nature with depreciation allowed. Section 14A interest disallowance failed where own funds exceeded investments, indirect expenditure was restricted to investments yielding exempt income, and the rule 8D amount could not be added back under section 115JB. Correct TDS credit was to be granted, and the captive power valuation adjustment under section 80-IA was deleted because market-rate valuation for captive consumption was accepted.</description>
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      <description>Industrial promotion assistance linked to setting up a new unit was treated as capital receipt because subsidy character depends on the scheme&#039;s purpose, not the mode of quantification, and was therefore not taxable as revenue income. Railway siding expenditure and the feeder-line enhancement component of power transmission were treated as revenue items subject to verification, while sub-station conversion and commissioning costs were capital in nature with depreciation allowed. Section 14A interest disallowance failed where own funds exceeded investments, indirect expenditure was restricted to investments yielding exempt income, and the rule 8D amount could not be added back under section 115JB. Correct TDS credit was to be granted, and the captive power valuation adjustment under section 80-IA was deleted because market-rate valuation for captive consumption was accepted.</description>
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