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Observation of Bench:

The fact that the assessee company belongs to the Baidyanath Group of Companies and main Baidyanath Group Company owned Thermal power plant also as stated by the Ld. AR during the hearing of the case and on this fact there Siddhayu Aayurvedic Research Foundation Pvt. Ltd.
was no rebuttal by the Ld. DR. In today's business scenario as a matter of business strategy backward/forward integration of the business entity itself or through its group companies is a common phenomenon. The fact that the assessee entered into the business of coal mining in the year 2006-07 and also provided loans to repay its debt is on record and there is no challenge to this fact by the revenue also. By various means the assessee tried to sustain the venture/business and ultimately, after almost 10 years, planned to quit the same as the same is found to be commercially non-viable. Here it make sense that one of the main group company is in electricity production through thermal power plant and another group company is developing the coal mining business for ensuring captive supply of the same to group generation company.