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2021 (4) TMI 1280

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..... ng Mills (P) Limited [ 2015 (4) TMI 132 - ITAT CHENNAI] as also on account of the fact that the legislature has by intent providing for taxing of the receipts from the sale of carbon credits under a special provision of Section 115BBG w.e.f 01.04.2018 and as the appeals relate to the period before this date, the receipts arising to the assessee herein on the sale of carbon credits is held to be c .....

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..... rders of the Ld. CIT(A) for assessment years 2010-11, 2011-12 2012-13 2013-14 against the action of the Ld. CIT(A) in confirming the action of the Ld. AO in treating the sale of carbon credits as Revenue Receipts, based on the decision in the case of Apollo Tyres Limited by ITAT Cochin Bench reported in (2014) 47 Taxmann.com 416. This Hon ble Tribunal decided this issue in favour of the assess .....

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..... ver inadvertently omitted to mention these assessment years in the order. Therefore, Para 22 of the impugned order is revised as under: 22. A perusal of the provision of Section 115BBG clearly shows the intention of the legislature to bring the income on the sale of the carbon credits to tax under the special provision. It is abundantly clear that the said receipts are not brought to tax under .....

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..... bunal in the case of Ambika Cotton Mills Limited and the decision in the Sri Velayudhaswamy Spinning Mills (P) Limited referred to supra as also on account of the fact that the legislature has by intent providing for taxing of the receipts from the sale of carbon credits under a special provision of Section 115BBG w.e.f 01.04.2018 and as the appeals relate to the period before this date, the recei .....

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