Allowing the appeal the Court held that the assessee had no other source of income except through generation and sale of power. All its receipts and expenditure related to a single activity of power generation. The interest received from the bonds issued by the Grid Corporation had a direct nexus with its essential business activity and, therefore, was income derived from interest is eligible for deduction. Order of High Court is affirmed. SLP of Revenue is dismissed. (AY.2002-03, 2003-04, 2007-08 to 2009-10)
ACIT v. Orissa Power Generation Corporation Ltd. (2024) 298 Taxman 273 (SC) Editorial : Orissa Power Generation Corporation Ltd v. ACIT (2022) 138 taxmann.com 341 / (2023) 456 ITR 495 (Orissa)(HC)
S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Generation of power-Interest on Bonds issued by Grid Corporation in lieu of unpaid energy bills-Eligible for deduction-Order of High Court affirmed-SLP of Revenue is dismissed. [S. 80IA (iv)(a),80IB, 80IC, Art. 136]