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2017 (5) TMI 424 - AT - Income TaxDeduction u/s 80IA - captive power generation unit - eligible profit of that unit - Held that:- As in assessee’s cases itself in A.Y. 2003-04 & 2004-05 deleted the impugned disallowance stating that the assessee was consuming power from two sources i.e GEB and Captive generation plant of its own. The GEB was being paid at the rate of 4.9 per unit while the power procured from Captive Unit installed by the assessee for the purpose of computing eligible profit the assessee has taken the market value of the power produced by Captive plant at the rate of 4.9 per unit. We noted that the similar issue has arisen before the Mumbai Bench of the Tribunal in the case of West Coast Paper Mills Ltd V/s JCIT reported in (2005 (6) TMI 547 - ITAT MUMBAI) in which the Tribunal, on this issue, what should be the price attributable to the power generated and consumed by the assessee for the purpose of computing the deduction available under section 80IA after availing the provisions of section 80IA (9). The cost of electricity produced by the assessee at Captive Unit may be taken at market value at ₹ 4.9 per unit for the purpose of computation of the eligible profit of that unit - Decided against revenue Addition made on account of provision made for bonus (assessment year wise) - Held that:- The above bonus is very much in the nature of an ascertained liability not to be added for the purpose of computing Section 115JB book profits. Shri Shinde fails to point out any distinction on the relevant facts in the two sets of assessment years in question. We thus decline this latter substantive ground as well.- Decided against revenue
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