https://www.taxtmi.com/caselaws?id=465674 Deduction under s.80-IA for power generation was denied on allegations of tax evasion and abnormal profit in one unit vis-à-vis other phases. The Tribunal held that where the deduction was accepted in the initial/earlier years and there was no change in facts, the claim could not be rejected subsequently; further, profit differentials were explained by fuel cost being borne by another group entity and by commercially expedient PPAs, and the tax-evasion theory failed as the major customer was loss-making and the assessee paid MAT. The disallowance under s.80-IA was rejected. Disallowance of managerial support service charges was held unsustainable since commercial expediency governs allowability and the Revenue failed to rebut evidence of services. The deletion of the addition was upheld. en-us Fri, 31 May 2019 00:00:00 +0530 Mon, 05 Jan 2026 20:18:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465674 Deduction under s.80-IA for power generation was denied on allegations of tax evasion and abnormal profit in one unit vis-à-vis other phases. The Tribunal held that where the deduction was accepted in the initial/earlier years and there was no change in facts, the claim could not be rejected subsequently; further, profit differentials were explained by fuel cost being borne by another group entity and by commercially expedient PPAs, and the tax-evasion theory failed as the major customer was loss-making and the assessee paid MAT. The disallowance under s.80-IA was rejected. Disallowance of managerial support service charges was held unsustainable since commercial expediency governs allowability and the Revenue failed to rebut evidence of services. The deletion of the addition was upheld. Case-Laws Income Tax Fri, 31 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465674