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<h1>Capital receipt: central outright grant subsidy treated as capital contribution to industrial units, not a revenue receipt.</h1> Amounts under the 10 per cent Central Outright Grant of Subsidy Scheme are treated as capital receipt because the subsidy is a contribution towards capital outlay, its quantum is determined with reference to fixed capital (with working capital excluded), and recipients must remain in production for a prescribed period, evidencing the capital character for income-tax purposes.