Long-term renewable energy project financing receipts treated as business income; s36(1)(viii) deduction allowed, 14A and TDS disallowances deleted. https://www.taxtmi.com/highlights?id=95769 Deduction under s.36(1)(viii) was allowed as the assessee's long-term financing of renewable energy projects qualified as "development of infrastructure facility" under the "eligible business" definition, and post-01.04.2000 no CBDT approval was required; consistency from later years also supported eligibility. Recharacterization of various receipts as "income from other sources" was rejected since interest on deposits and staff loans, service/consortium fees, swap gains, refunds/write-backs and related miscellaneous items were inextricably linked to the financing business or taxable as business income u/s 41(1); accordingly assessed as business income. Disallowance u/s 14A was deleted for want of AO's recorded satisfaction and absence of exempt income. Depreciation was allowed on beneficial ownership. Disallowance u/s 40(a)(ia) for short TDS deduction was held inapplicable. - ITAT en-us Tue, 06 Jan 2026 08:47:38 +0530 Tue, 06 Jan 2026 08:48:45 +0530 TaxTMI RSS Generator Long-term renewable energy project financing receipts treated as business income; s36(1)(viii) deduction allowed, 14A and TDS disallowances deleted. https://www.taxtmi.com/highlights?id=95769 Deduction under s.36(1)(viii) was allowed as the assessee's long-term financing of renewable energy projects qualified as "development of infrastructure facility" under the "eligible business" definition, and post-01.04.2000 no CBDT approval was required; consistency from later years also supported eligibility. Recharacterization of various receipts as "income from other sources" was rejected since interest on deposits and staff loans, service/consortium fees, swap gains, refunds/write-backs and related miscellaneous items were inextricably linked to the financing business or taxable as business income u/s 41(1); accordingly assessed as business income. Disallowance u/s 14A was deleted for want of AO's recorded satisfaction and absence of exempt income. Depreciation was allowed on beneficial ownership. Disallowance u/s 40(a)(ia) for short TDS deduction was held inapplicable. - ITAT Highlights Income Tax Tue, 06 Jan 2026 08:47:38 +0530 https://www.taxtmi.com/highlights?id=95769