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.(AY.2002-03, 2003-04, 2007-08 to 2009-10)
Odisha Power Generation Corporation Ltd. v. ACIT (2023)456 ITR 495 /[2022] 138 taxmann.com 341(Orissa)(HC)/Editorial : SLP of Revenue is dismissed , ACIT v. Orissa Power Generation Corporation Ltd. (2024) 298 Taxman 273 (SC)
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. [S.80IA (iv)(a),80IB, 80IC]