Expert Advisory Committee
ICAI-Expert Advisory Committee
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Query No. 28

Subject:

Accounting treatment for wind mill project set up to

produce power for captiveconsumption.1

A. Facts of the Case

1. A public sector undertaking is engaged primarily in the extraction and sale of manganese ore from its mines in two States. It also produces and sells ferro manganese, a value added product at one of its mines in one of the States by using a small quantity of its manganese ore production as principal raw material.

2. The company has recently ventured into generation of electricity by installation of wind turbine generators in one of the States. The company has entered into an agreement with another company (which installed and commissioned the generators) for operating the wind turbine generators by paying operations and maintenance charges.

3. The existing regulations framed by the State Government permitted the company to opt for any one of the following:
           

(a) Direct sale of electricity to X State (Western Region) Electricity Distribution Company Ltd., at the rates decided by the regulatory authority.
           

(b) Use of the power units generated at the Wind Mills Project (WMP) for the company’s own activities at any other location in State X by transmitting the power generated to grid through the X State (Western Region) Electricity Distribution Company Ltd., and drawing 98% of the units generated from the X State (Eastern Region) Electricity Distribution Company Ltd., for its specified consuming units. In this case, the company enters into an agreement with various arms of the X State Government, viz., (i) X State (Western Region) Electricity Distribution Company Ltd. (where power is generated), (ii) X State Power Transmission Company Ltd. (through which power is transmitted) and (iii) X State (Eastern Region) Electricity Distribution Company Ltd., (where actual consumption is made).

4. As the company is in a position to get more benefit by way of reduction in electricity bills of consuming units as compared with direct sale of electricity, the company has opted for (b) above. The company has identified one of its manganese mines and ferro manganese plant as its specified consuming unit. By virtue of the agreement with the above distribution/transmission arms of the electricity companies (hereafter referred to as ‘XEDCL’), gross consumption by manganese mine and ferro manganese plant is reduced by actual power generated at the WMP less 2% towards wheeling charges/transmission and distribution losses. Thus, the company gets electricity bills of specified consuming units for net amount payable to XEDCL.

5. Further, if the actual consumption at the consuming units is less than the units generated at the WMP, the reduction in power units is restricted to actual consumption at the consuming units. The additional units generated, termed as “inadvertent flow”, are compensated at a specified fixed rate per unit by the distribution company.

6. The querist has stated that although the revenue generated from the project is not substantial in relation to the total turnover of the company, the investment in the project is more than 10% of its gross block of assets. In view of this and the fact that the risks and rewards of the new venture are different from that of the existing business, the company considers the WMP as a separate reportable segment.

7. The querist has stated that the company considers the following accounting treatment and presentation to be appropriate and in line with the accounting standards:
       

(i) Since the ultimate consumers are units of the company itself, the transaction shall not be termed as ‘sale of electricity’.
           

Consumption of products of one of the units by other units, commonly referred to as ‘captive consumption’, is generally charged to other units as the cost of production of the producing unit. However, in this case, the revenue generated from the project shall be disclosed separately under the heading ‘other income’ in the profit and loss account for the following reasons–
           

(a) The reduction allowed in electricity bills by XEDCL towards units generated at WMP, which otherwise would have been charged to consuming units at normal power tariff rates, represents gain realised ‘in cash’ as distinguished from a mere book adjustment.
           

(b) Power generated by the company goes into the grid and loses its identity there itself (as distinguished from a case where the same commodity is transported to another location).
          

(c) Power generating/consuming company, power receiving company and power distributing company are three different legal entities involved in the transaction and a third party (XEDCL) is quantifying the value of electricity generation.
        

In view of the above, the net reduction in electricity charges of the two divisions, i.e., ferro manganese plant and manganese mine, equal to the value of credit given by XEDCL in its monthly bills, shall be treated as revenue generated from the project. Further, in the event of generation at WMP exceeding the consumption at consuming units, amount credited by XEDCL in electricity bills shall also be treated as revenue generated from the project and shall also be treated as ‘other income’.
        

The querist has furnished a statement containing extracts from the electricity bill for November 2006 for the perusal of the Committee to explain the methodology. As against the gross bill of Rs. 39,14,579, the company is required to pay only Rs. 26,85,455 thus resulting in reduction of Rs. 12,29,124 towards power generation at WMP. This sum of Rs. 12,29,124 shall be treated as revenue generated from the project.
        

Separate accounting of 2% wheeling charges on expenditure side, by grossing up revenue, is not considered necessary because the reduction is made by XEDCL at generation point and accounting on expenditure side will pose difficulty in allocation of the charges to consuming units.
       

(ii) Operations and maintenance charges are payable after a specified period at agreed rate per machine on annual basis. Besides this, administrative expenses like rates and taxes, inspection fees, etc., are to be borne by the company right from the first year of operation. All the above expenses shall be disclosed separately in the profit and loss account as expenditure of wind mills division.
       

(iii) Depreciation on WMP assets shall be indicated separately below the fixed assets schedule in line with the practice followed by the company in respect of manufacturing units.

       

(iv) Ferro manganese plant and mine will not be charged with actual cost of generation of electricity at WMP because (a) these units continue to consume the same quantity of power (b) the credit given by the XEDCL in electricity bills of these units towards electricity generation at WMP represents gain realised in cash, (c) power generating/consuming company, power receiving company and power distributing company are three different legal entities involved in the transaction and a third legal entity (XEDCL) is quantifying the value of electricity generated and (d) profit centre concept does not permit such an adjustment.         

In view of the above, the company shall also value stock of manganese ore and ferro manganese by considering gross cost of power at these power consuming units without deduction of credit given by XEDCL in electricity bills.
        

(v) Net profit from operating wind mills, after deducting operational/ administrative expenses and depreciation, shall be disclosed in segment reporting and memorandum profit and loss account separately.

B. Query

8. In view of the above, the querist has sought the opinion of the Expert Advisory Committee specifically on the issue of the treatment of reduction in electricity bills on account of credit given by XEDCL in electricity bills towards generation of electricity at wind mills division.

C. Points considered by the Committee

9. The Committee notes from paragraph 8 above that the querist has raised the issue only with respect to the treatment of reduction in electricity bills on account of credit given by XEDCL in the electricity bill towards generation and supply of electricity by the company through its wind mill division. The Committee has, therefore, considered only this issue and has not considered or touched upon any other issue arising from the Facts of the Case, such as, segment reporting for wind mill division, treatment of various expenses of the wind mill division, disclosure of depreciation on the assets of the wind mill division, etc.

10. The Committee notes from the Facts of the Case that the company is not selling the power generated at its wind mill division. Rather, the company is using the power generated at the wind mill division for the company’s own activities at another location. For this purpose, the company is transmitting the power generated through a distribution company. The extracts from the agreement with the distribution company furnished by the querist also indicate that the power is being transmitted by the company to the distribution company for its self-use only. For this purpose, wheeling charges in the form of 2% of the energy fed into the system by the company, are paid to the distribution company. Thus, the company is drawing only 98% of the energy fed into the system for its selfuse at a different location. The energy drawn above this limit is charged to the company separately. In case, a lesser quantity of energy is drawn by the company, the company is compensated for the excess units generated at specified rates. The Committee notes that the distribution company in the electricity bill sent to the company shows charges for the full energy drawn by the company and then gives a credit for 98% of the energy that was actually fed into the system by the company itself. The Committee is of the view that this is only a manner of disclosure in the electricity bill. It does not amount to sale and purchase of energy to and from the distribution company. Thus, the Committee is of the view that the energy drawn by the company for its self-use is only an interdivisional transfer from the wind mill division to its consuming divisions, though at a different location.

 

11. The Committee notes that the querist has argued in paragraph 7 above that the net reduction in electricity charges of the consuming divisions equivalent to the 98% of the energy fed into the system by the company by its wind mill division, should be treated as revenue generated by the wind mill division. In this context, the Committee notes the definition of the term ‘revenue’ as per Accounting Standard (AS) 9, ‘Revenue Recognition’, which is reproduced below:
           

“4.1 Revenue is the gross inflow of cash, receivables or other consideration arising in the course of the ordinary activities of an enterprise from the sale of goods, from the rendering of services, and from the use by others of enterprise resources yielding interest, royalties and dividends. Revenue is measured by the charges made to customers or clients for goods supplied and services rendered to them and by the charges and rewards arising from the use of resources by them. In an agency relationship, the revenue is the amount of commission and not the gross inflow of cash, receivables or other consideration.”

The Committee is of the view that as per the definition of the term ‘revenue’ as reproduced above, inter-division transfers do not constitute revenue. The Committee further notes that as per an Announcement issued by the Institute of Chartered Accountants of India in the year 2005, titled ‘Treatment of Inter-divisional Transfers’, transfers within an enterprise cannot be considered as fulfilling the definition of the term ‘revenue’.

 

12. The Committee also notes that the reduction in the electricity bills of the consuming units does not constitute ‘income’ for the company. In this context, the Committee notes that the Framework for the Preparation and Presentation of Financial Statements, issued by the Institute of Chartered Accountants of India, defines the term ‘income’ as “increase in economic benefits during the accounting period in the form of inflows or enhancements of assets or decreases of liabilities that result in increases in equity, other than those relating to contributions from equity participants”. The Committee is of the view that selling to itself does not result in enhancement of assets and, therefore, the reduced electricity bills do not fit into the definition of the term ‘income’ as above. Accordingly, it is not appropriate to present the same as ‘other income’.

13. The Committee is of the view that the expenditure incurred by the wind mill division together with the electricity charges paid by the consuming divisions to the distribution company for excess electricity drawn, would represent the cost on account of electricity charges of the consuming divisions. Thus, no separate accounting entries need be passed for the saving in cost towards electricity charges. However, it may be noted that to the extent of the ‘inadvertent flow’ of electricity to the XEDCL (referred in paragraph 5 above), the compsensation received towards the same would be treated as sale of electricity and appropriately disclosed in the profit and loss account.

D. Opinion

14. On the basis of the above, the Committee is of the opinion that the accounting treatment suggested by the querist for the reduction in the electricity bills on account of credit given by the distribution company in electricity bills towards generation and supply of electricity by the wind mill division, is incorrect. The correct treatment would be as given in paragraph 13 above.

 

1Opinion finalised by the Committee on 30.1.2008.