LAKSHMI MACHINE WORKS LTD.,COIMBATORE vs. DCIT COMPANY CIRCLE I, COIMBATORE

ITA 2094/CHNY/2017Status: DisposedITAT Chennai03 July 2026AY 2013-1410 pages
AI SummaryAllowed

What were the facts?

The assessee claimed deduction under Section 80-IA for power generated through windmills for captive consumption. The TPO proposed a downward adjustment to the deduction by re-benchmarking the transfer of wind energy based on the power purchase rate of the State Electricity Board.

What did the Tribunal hold?

The Tribunal held that the market value for inter-unit transfer of electricity should be the rate at which the State Electricity Board supplies power to industrial consumers, not the rate at which it purchases power from generators. The TP adjustment made by the TPO was deemed incorrect.

What were the issues?

The primary issue was the correct method for benchmarking the arm's length price of electricity transferred between units for the purpose of Section 80-IA deduction, specifically whether to use the State Electricity Board's consumer tariff or its purchase rate from generators.

Which sections of the Income-tax Act were involved?

Section 80-IA,Section 92C(4),Section 143(3),Section 144C(13)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

For Respondent: Mr. K. Jayaganesh, CIT

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the final order of the assessment passed by Dy. Commissioner of Income Tax, Corporate Circle-1, Coimbatore (in short "AO") passed u/s. 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 (in short "the Act") dated 30.06.2017 for Assessment Year (AY) 2013-

14.

The assessee raised the following grounds of appeal: “(1) The impugned order u/s 143(3) rws 144C(13) of the AO, is contrary

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 80-IA

All 591 judgments and leading authorities on Section 80-IA →

Recent GST High Court judgments

Search GST case law →