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INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
WASEEM AHMED, Accountant Member, KESHAV DUBEY, Judicial Member
Sokke Kaliveerappa Shivaraj – Appellant
Versus
Asst. Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. assessee claimed 80-ia deduction on gbi incentive disallowed by ao. (Para 2 , 3 , 4 , 5) |
| 2. gbi directly linked to power generation, eligible for 80-ia. (Para 6) |
| 3. cit(a) confirmed disallowance; gbi not 'derived from' business. (Para 7) |
| 4. dr supported revenue; gbi policy-driven, not operational. (Para 8) |
| 5. gbi has direct nexus with generation, eligible for 80-ia deduction. (Para 9) |
| 6. assessee's appeal partly allowed. (Para 10) |
ORDER
PER WASEEM AHMED, ACCOUNTANT MEMBER:
The present by the assessee for the A.Y. 2017-18 is directed against the order passed under section of 250 of the Income Tax Act 1961 (hereafter the Act) dated 2nd September 2025 by the learned Commissioner of Income Tax-Appeal (hereafter- learned CIT-A) at National Faceless Appeal Centre-NFAC.
2. The assessee in the appeal memo has raised as many as 12 grounds of appeal. However, the issues raised therein are interconnected and pertain of disallowances of deduction under section 80-IA of the Act on “Power Generation Incentive”.
3. The facts in brief are that the individual assessee is engaged in the business of wind power generation and claimed deduction u/s 80-IA of the Act. During the assessment proce
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