Power purchase agreement fixed capacity charges treated as generation profits; Section 80IA deduction allowed on full receipts, appeal dismissed

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....Fixed capacity charges received under a power purchase agreement were held to be profits "derived from" the business of generation and supply of electricity, since the undertaking's sole business was power generation and the charges were inextricably linked to assured capacity allocation; mismatch with actual offtake could not justify restricting deduction to variable charges alone. Deduction under section 80IA was therefore allowable on the entire eligible business receipts, including annual fixed charges. Invocation of section 80IA(10) alleging a colourable device was rejected because the specified domestic transactions were found at arm's length, and the arrangement reflected industry and regulatory pricing norms; the Revenue's appeal was dismissed. - ITAT....