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3.26 The reliance by the State Commission in the oral arguments on the decisions of the Hon'ble Supreme Court in relation to tax benefits in misplaced. The tax is collected by the sovereign and it is for the sovereign to decide to give any exemptions, remissions, concessions etc. There are not specified criteria based on which the exemptions can be given.

3.27 The reliance on the decision of this Tribunal in the case of Northern Railway v DERC, Appeal No. 268 of 2006 dated 13/03/2007 to contend that this Tribunal has approved the differentiation based on old consumer and new consumer is misplaced. The comparison was between Indian Railways and Delhi Metro Rail Corporation, which are two very different consumers. DMRC is a mass rapid transport system for the city, the Railways is for the country as a whole. Railways has a very substantial network, been in place for aver 150 years, has financial strength and can maintain operations at existing level with nominal increase. Considering all of these, the different categories was approved. (Para 17 and 18) 3.28 There was no differentiation on the sole ground that one consumer is an existing consumer and the other is a new consumer. This Tribunal has in fact gone on various factors including the viability of DMRC, the requirements of DMRC, the nature of DMRC and the age of Railways etc. to provide for the different classification.

4.5 It is submitted that same differentiation in tariff determination has been previously allowed by this Tribunal in the matter of Northern Railway v. Delhi Electricity Regulatory Commission in Appeal No. 268 of 2006. The application of the said case to the present facts is evident from the table below:

Application of APTEL Order in Northern Railway v. Delhi Electricity Regulatory Commission Differentiation APTEL's Northern Present Case Railway Order Differentiation Differentiation between Differentiation between between new old (Northern Railway) new and old industries and old and new consumer for propose of giving (DMRC) for tariff given. In rebate Para 9 (b)of the this Tribunal's Order, Delhi Electricity Regulatory Commission ("DERC") explained the basis of differentiation by stating that DMRC is a new consumer.

Paragraph 3 of the APTEL Order records that the grievance of Northern Railway was that it has been discriminated against in as much as it had been made to pay tariff at a rate higher than that paid by DMRC.

                       Although DERC's Order
                       did not specifically deal
                       with the reasons for
                       differentiation     in   the
                       Order, DERC explained




                 the differentiation in its
                 reply.
Appellant's      In para 16 of its Order this     In the present case
objection to     Tribunal holds that DMRC         differentiation is doneto
differentiation: is new consumer and is           promote new industries
basis of age     still in the process of          in the State and to
                 building its infrastructure &    maximize consumption
                 therefore, the impact of         of    surplus      energy
                 tariff on it is much higher      within the State so as
                 than the impact of tariff on     to minimize on the
                 the      appellant.       This   fixed cost of un-
                 Tribunal noted that the full     dispatched/surplus
                 meaning of the words "a          power.
                 new consumer of 220 kV           The new Industries
                 and     its    differentiating   require creation of new
                 nature of service" in the        infrastructure, market
                 tariff Order for financial       etc. which necessitates
                 years 2002-03 and 2003-          huge               capital
                 04 can be explained and          investment.       (Please
                 understood in this context.      refer to Page 234,para
                                                  13 of the Appeal)
Objection of      Para      17      of     the    The Appellant in the
the Appellant     APTELOrder records that         present case contests
against           Northern Railway disputed       that new industries
differentiation   that DMRC can be treated        cannot be treated as a
on basis of       as a preferred class only       preferred class only
new and old       because it is a new             because they are new
                  consumer at 220 kV. It          consumers and that
                  was      contended        by    this differentiation does
                  Northern Railway that the       not        fall     within
                  comparative age of the          differentiation     under
                  consumers is not a criteria     Section 62(3) of EA
                  for differentiation under       2003.
                  Section 62(3) of EA 2003.
Contention of     Para 17 of the APTEL            The Appellant contests
Appellant is      Order      records      that    that it too like the new
that              Northern            Railway     industries      has     a
expansion of      contended that it is            business to run and
business is       constantly expanding its        expand          therefore
required by       services reach etc., and        differentiation cannot
old industries    also has to undertake           be made on the ground
                  substantial    expenditure      that the new industries
                  every     year       towards    need to create new




                 building                 new     infrastructure
                 infrastructure.
New              This Tribunal holds in para      Unless        the     new
industries       17 that the arguments of         industries are treated
have to          Northern Railway when            preferentially, they will
compete          examined closely lose            not be able to compete
against          their     force.    Northern     with the older well
established      Railway is an established        established industries.
industries       organisation.         Unless     Further the purpose of
                 DMRC           is     treated    supply of electricity to
                 preferentially, its viability    the old industries is to
                 itself may be at stake. The      enable        them      to
                 purpose of supply of             continue              their
                 electricity to the two           operations             and
                 organisation can thus be         nominal increase in
                 distinguished. The DMRC          growth         of     their
                 can be distinguished from        business.         However,
                 the appellant in terms of        the purpose of supply
                 age. The purpose of              of electricity to the new
                 supplying electricity to the     industries is to set an
                 two organisations namely         altogether new project
                 the Appellant and DMRC           which is also termed
                 can also be said to be           as a green field
                 different. For Appellant the     project. Setting up
                 purpose of supply of             green field project is a
                 electricity is to maintain its   huge        infrastructure
                 operation at the existing        cost and thus the new
                 level except for the             industries           merit
                 nominal increase by the          preferential treatment.
                 year whereas the purpose
                 of supply of electricity to
                 DMRC is to create an
                 altogether new transport
                 system for the City of
                 Delhi.

vi) The first Respondent/the State Commission has placed reliance on the judgment of this Tribunal in the case of Northern Railway v DERC, Appeal No. 268 of 2006 dated 13/03/2007 wherein it is noticed that there is no similarity between the case considered in the Appeal No. 268 of 2006 and the present Appeal. In Appeal No. 268 of 2006, the issue is between the Northern Railway and the new consumer 'Delhi Metro Rail Corporation'. It is to be kept in mind that whereas Northern Railway and the Delhi Metro Rail Corporation both use electricity for the purpose of traction but their nature of service is different.