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    <title>2026 (8) TMI 135 - ITAT MUMBAI</title>
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    <description>Internal CUP based on electricity tariffs paid by consuming units to State distribution companies is presented as the appropriate benchmark for captive power transfers. The notes also state that section 14A disallowance requires a borrowing nexus for interest expenditure and confines administrative expenditure to investments yielding exempt income, while MAT adjustments require independently identified expenditure. Expansion-related operating costs are treated as revenue expenditure, and unsupported technical-services pricing adjustments are rejected. Captive rail systems and an acquired running power undertaking qualify for section 80-IA relief, subject to nexus-based common-cost allocation. Industrial incentives linked to investment and expansion are characterised as capital receipts and excluded from book profit where not income. The notes further address investment allowance, additional depreciation, actual bad-debt write-offs, and limits on leave-encashment and income-tax-interest deductions.</description>
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    <pubDate>Wed, 29 Jul 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=796262</link>
      <description>Internal CUP based on electricity tariffs paid by consuming units to State distribution companies is presented as the appropriate benchmark for captive power transfers. The notes also state that section 14A disallowance requires a borrowing nexus for interest expenditure and confines administrative expenditure to investments yielding exempt income, while MAT adjustments require independently identified expenditure. Expansion-related operating costs are treated as revenue expenditure, and unsupported technical-services pricing adjustments are rejected. Captive rail systems and an acquired running power undertaking qualify for section 80-IA relief, subject to nexus-based common-cost allocation. Industrial incentives linked to investment and expansion are characterised as capital receipts and excluded from book profit where not income. The notes further address investment allowance, additional depreciation, actual bad-debt write-offs, and limits on leave-encashment and income-tax-interest deductions.</description>
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