RAUA received on transfer of undertaking not taxable in hands of ‘Adani’ due to diversion of income by overriding title

INCOME TAX : Where applicant seeks to know about taxability of RAUA (regulatory assets under approval) retained by Rinfra while transferring Generation, Transmission and Distribution (GTD) undertaking to applicant-AEML, and which will be recovered by AEML in trust for and on behalf of Rinfra, RAUA received by AEML will not be liable to tax in hands of AEML but will be taxable in hands of Rinfra on account of diversion of income by overriding title

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