https://www.taxtmi.com/caselaws?id=790339 For section 80-IA valuation, captive power transfer price had to be benchmarked against the open-market tariff charged by the State Electricity Board to industrial consumers, so the embedded electricity duty could not be artificially excluded. Section 80-IA(9) barred only double deduction on the same profits and did not justify reducing independent power profits while computing section 80HHC relief; the adjustment was therefore unwarranted. Sales tax remission under the incentive scheme was held to be a capital receipt because it was intended to induce fresh investment and expansion in a backward area, and as capital receipt it could not be included in book profits under section 115JB. Relief was granted to the assessee on all issues. en-us Tue, 21 Apr 2026 00:00:00 +0530 Thu, 23 Apr 2026 09:45:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790339 For section 80-IA valuation, captive power transfer price had to be benchmarked against the open-market tariff charged by the State Electricity Board to industrial consumers, so the embedded electricity duty could not be artificially excluded. Section 80-IA(9) barred only double deduction on the same profits and did not justify reducing independent power profits while computing section 80HHC relief; the adjustment was therefore unwarranted. Sales tax remission under the incentive scheme was held to be a capital receipt because it was intended to induce fresh investment and expansion in a backward area, and as capital receipt it could not be included in book profits under section 115JB. Relief was granted to the assessee on all issues. Case-Laws Income Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790339