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2015 (11) TMI 1866 - AT - Income TaxDeduction u/s 80IA in respect of income from generation of power and sale of carbon credit - AO held that the sale on “carbon credit” was neither having direct nor having immediate nexus with the income from power generation division of the assessee, therefore, profit on sale of carbon credit was not eligible for claiming deduction u/s 80IAWhether deduction is eligible for ‘power’ and not for ‘carbon credit'? - HELD THAT:- On identical facts and circumstances, we have already decided this issue in the case of ACIT, Raipur Vs Bajrang Power & Ispat Ltd.1[2015 (11) TMI 1865 - ITAT RAIPUR] holding that the income on sale of carbon credit was derived from the activity of the industrial undertaking. Disallowance on account of temple & pooja expenses when the expenses on temple and pooja are personal and not for the welfare of the employees - HELD THAT:- We have noticed that the AO has not pointed out any specific reason that why the expenditure in question was not admissible; specifically when the claim of the assessee was that the same were wholly and exclusively incurred for the purpose of assessee’s business. In a very cryptic manner, he has held that the purpose of the travel was not explained and the temple and pooja expenditure are personal and not for welfare of the employees. Hence, he had made disallowance respectively on ad-hoc basis. When the matter was carried before the first appellate authority, the learned CIT(A) has reversed the impugned ad-hoc disallowance on the ground that even on verification of bills and vouchers, no specific instance was mentioned by the AO in support of the said disallowances. We are also of the view that estimation in question pertaining to travelling expenses and temple & pooja expenses was not based upon any cogent evidence. As a result, we hereby confirm the findings of the learned CIT (A) and dismiss these two grounds of appeal of the Revenue.
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