1.	 Starting date is 30/06/2009 then why revenue estimates have been made for the year 2008-09? What is the period of operation in 2008-09?
2.	Revenue estimates have been considered for more than 20 years which is more than the estimated life of the project. Why 2008-09 is taken as year ZERO when there is revenue?
3.	Interest for the year 2008-09 is Zero. No loan utilized? Then how the investment is assumed to be made?
4.	Tax holiday under section 80IA considered beyond 15 years from the year of commissioning (2008-09)?
5.	There is a WDV of Rs.4.25 Lakhs for incometax purposes at the end of the year 2011-12. Why no depreciation is provided on the same for subsequent years?
6.	No costs incurred for land? If it is included in the project cost, the same is to be segregated and no depreciation shall be provided on the same.
7.	Depreciation for the year 2008-09 is only Rs.0.64 Lakh. Is it on prorata basis? For the subsequent years it is Rs.39.15 Lakhs p.a
8.	Even when no tax under regular provisions of Income-tax Act, 1961 is payable, MAT is payable on book profits for the years 2022-23 and 2023-24.
9.	Salvage value of the assets considered for IRR workings seems to be very less.  The COP is Rs.879.20 Lakhs and book depreciation is Rs.783.64 Lakhs. The fair value of residual assets would be Rs.95.56 Lakhs. But residual value of assets is taken as Rs.9.00 Lakhs. What is the basis?
10.	How Post tax equity IRR is compared with pretax bench mark?
11.	For Equity IRR workings, COP is taken as Rs.444.00 Lakhs ony, being the equity, whereas all the term loan repayments are netted from the cash flow.

How can the DOE webhost such a incomplete PDD which is not at all transparent? None of the input parameters are justified in the PDD. This is deliberately done by the PP and overlooked by the DOE. THis defeats the purpose of transparency in CDM! EB to note such instances of webhosting of PDDs which are not at all transparent!

The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax 

shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. 

This is evident from the recently registered projects and those requesting registration.  
The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been 

taken into account and confirm the accounting of the cash inflows as a result of the negative tax 

liability in the initial years. DOE should not be misguided by the financial presented by the PP or 

consultant which are custom made for CDM purposes and not the actual financial considered at the 

investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable 

venture.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so 

that the third party report may indicate a lower PLF. The third party report can be forge just to indicate 

a lower PLF. Also cross check with tariff order.


Is PP also claiming REC? How can DOE ensure that REC is not claimed during project operation?

Land cost and insurance cost seems to be high. Compare with actual costs.

The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  

The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF.
The PLF seems to be very low. Also check the tariff order.


Benchmark: 
No details are provided on the beta estimation. Is the beta levered or unlevered and what is the reason?? How is the beta appropriate for irr chosen?

Stakeholder consultation:
No details provided on which all stakeholders attended the meeting. 

Benchmark:
The benchmark is too high. Even after considering CDM benefits the IRR will not cross the benchmark. Then WHY did the PP go ahead with this non-profitable venture??
This clearly indicates the benchmark is made high just to prove additionality and is not the real benchmark expected by the PP.

Why has the PP considered Reliance Infrastructure Ltd for beta determination when Reliance Infrastructure Ltd. has many other businesses other than pure power generation? How come the risk profile of Reliance Infrastructure Ltd match with the project activity which involves wind electricity generation?

What is the vintage considered for beta determination? Is considering only one year appropriate?
Why tax computations for beta are only considered for one year?? What is the basis for considering a particular vintage for the market returns, beta estimation and risk free returns?

Why the particular index is considered for calculating the market returns? DOE to evaluate whether the PP has made any other investments considering the same index. Only because a particular index results in a higher benchmark??

Project cost seems to be very high. Are the quotations real or fabricated?

Are REC benefits being claimed? How will the DOE ensure that the PP does not claim REC benefits during project operation?

DOE to submit a negative opinion in case the IRR does not cross the benchmark even after considering CDM benefits as it clearly indicates the projects unviability in any case. Why would any one invest in a loss making venture? 

And if the PP can still go ahead with the project - it indicates that the benchmark is fabricated and is not considered by the PP while making the investment decision!! DOE to validate this critically!! How are the investment decisions really made???

DOE to check if the financials correctly apply the 10 year tax holiday - i.e. not liable for taxes for 10 years from the initial 15 years. PP may show taxation with the logic of cumulative losses - which is totally incorrect!!

The PP states that they have considered 80% accelerated depreciation. However the PDD is silent on the tax shielding as a result from accelerated depreciation.
PPs cleverly do not consider the accounting tax offsetting in their companies while calculating the IRR. This is evident from the recently registered projects and those requesting registration.  

The DOE is therefore requested to critically analyze how the accelerated depreciation benefit has been taken into account and confirm the accounting of the cash inflows as a result of the negative tax liability in the initial years. DOE should not be misguided by the financial presented by the PP or consultant which are custom made for CDM purposes and not the actual financial considered at the investment decision.
Note that considering cash inflows results in an increase in the IRR making wind projects a profitable venture.

Please also check the offer from WTG supplier and Purchase Order while validating the PLF. It may be so that the third party report which is made after investment decision making - indicates a lower PLF.
The PLF seems to be very low. Also check the tariff order.


Benchmark: 
No details are provided on the beta estimation. Is the beta levered or unlevered and what is the reason?? How is the beta appropriate for irr chosen?

Stakeholder consultation:
No details provided on which all stakeholders attended the meeting. 

Benchmark:
The benchmark is too high. Even after considering CDM benefits the IRR will not cross the benchmark. Then WHY did the PP go ahead with this non-profitable venture??
This clearly indicates the benchmark is made high just to prove additionality and is not the real benchmark expected by the PP.

Why has the PP considered Reliance Infrastructure Ltd for beta determination when Reliance Infrastructure Ltd. has many other businesses other than pure power generation? How come the risk profile of Reliance Infrastructure Ltd match with the project activity which involves wind electricity generation?

What is the vintage considered for beta determination? Is considering only one year appropriate?
Why tax computations for beta are only considered for one year?? What is the basis for considering a particular vintage for the market returns, beta estimation and risk free returns?

Why the particular index is considered for calculating the market returns? DOE to evaluate whether the PP has made any other investments considering the same index. Only because a particular index results in a higher benchmark??

Project cost seems to be very high. Are the quotations real or fabricated?

Are REC benefits being claimed? How will the DOE ensure that the PP does not claim REC benefits during project operation?

DOE to submit a negative opinion in case the IRR does not cross the benchmark even after considering CDM benefits as it clearly indicates the projects unviability in any case. Why would any one invest in a loss making venture? 

And if the PP can still go ahead with the project - it indicates that the benchmark is fabricated and is not considered by the PP while making the investment decision!! DOE to validate this critically!! How are the investment decisions really made???

DOE to check if the financials correctly apply the 10 year tax holiday - i.e. not liable for taxes for 10 years from the initial 15 years. PP may show taxation with the logic of cumulative losses - which is totally incorrect!!