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of The ITAT dismissed the revenue's appeal, holding that the fertilizer subsidy received by the assessee under the NBS policy is a capital receipt not chargeable to tax. The ITAT followed its earlier decision in the assessee's case for AY 2015-16, where it was held that the scheme's purpose was to attract investment in the industry and make fertilizers available to farmers at appropriate prices, which could only be achieved by bringing new investments. The ITAT reiterated that this is a recurring issue already adjudicated in favor of the assessee.
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