M. P POLICE SAKH SAHKARI SANSTHA MARYADIT UJJAIN,UJJAIN vs. INCOME TAX OFFICER -2(1), UJJAIN

In the result appeal of the assessee is dismissed

Bench: Shri Manish Boradm.P. Police Sakh Sahakari Ito 2(1), Sanstha Maryadit, Ujjain 32Nd Battalion, Vs. Dewas Road Nagari, Ujjain (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabam5551C Assessee By Shri Milind Wadhwani, Ar Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 27.02.2025 Date Of Pronouncement 28.02.2025 O R D E R

section 80J. In our view, since the expression of wider import, namely, "attributable to", has been used, the legislature intended to cover receipts from sources other than the actual conduct of the business of generation and distribution of electricity’ 10. Therefore, the word "attributable to" is certainly wider in import than the expression "derived from". Whenever the legislature wanted