That for the purpose of deduction under section 80IA(4) power should be construed in common parlance as “energy”. “Energy” can be in any form being mechanical, electricity, wind or thermal. In such circumstances, the “steam” produced by the assessee could be termed as power and would qualify for the benefit available under section 80IA(4) of the Act. The order of the Commissioner (Appeals) affirmed.  That regarding allocation of cost between high power steam and low power steam, once the assessee had claimed relevant cost of the power plant and recognized revenue for generation of power and steam at specific values and the Assessing Officer had not brought any evidence that the steam value charged from the other unit was not at market value, the Assessing Officer was not empowered to re-compute the profit and loss account of the eligible unit. There was no need to prepare/recast the profit and loss account or compute excess low power cost recovered from paper units as made by the Assessing Officer as well as by the Commissioner (Appeals). The method of cost re-allocation for high power steam and low power steam initially worked out by the Assessing Officer and further method of allocation of cost made by the Commissioner (Appeals) were to be set aside. (AY.2007-08 to 2013-14).