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TMI Blog2019 (4) TMI 624X X X X Extracts X X X X X X X X Extracts X X X X ..... T] no hesitation in accepting the plea of the assessee that the Commissioner committed serious error in dissecting the tariff to come to the conclusion that the tax component specified as part of the tariff is reimbursement of the liability of the assessee and hence it would not form part of the income. As already pointed out, when the Revenue had not questioned the genuineness of the agreemen ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al question of law has been framed:- Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that components of price for sale of electricity fixed on basis of tax liability should not be taken as part of sale price of electricity in computing relief under Section 80IA? 2. Mr.R.Vijayaraghavan, learned counsel appearing for the appellant/assessee and Mr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 999 entered into between the assessee and the various State Electricity Boards thus show the modalities of arriving at the tariff which includes the tax liability of Neyveli Lignite Corporation. Thus, it is evident that the tariff that was arrived at between the parties consisted of various components including tax liability on the income streams from the core activity of NLC and the quantifi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssioner committed serious error in dissecting the tariff to come to the conclusion that the tax component specified as part of the tariff is reimbursement of the liability of the assessee and hence it would not form part of the income. As already pointed out, when the Revenue had not questioned the genuineness of the agreement between the parties and liberty is thus available for the parties to ar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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