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    <title>2019 (1) TMI 1195 - ITAT RAIPUR</title>
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    <description>Financial assistance received from the State fund for development of a coal block was treated as a capital receipt because it was sanctioned to facilitate setting up and development of the mining project, not to meet routine business expenses. Applying the purpose test for subsidies and grants, the assistance was linked to capital infrastructure rather than revenue operations. On identical facts, the receipts had already been assessed as capital receipts in earlier scrutiny years, and in the absence of any material change, a contrary view for the year under review was unsustainable. The receipt was therefore not chargeable to tax, and the addition was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=374030</link>
      <description>Financial assistance received from the State fund for development of a coal block was treated as a capital receipt because it was sanctioned to facilitate setting up and development of the mining project, not to meet routine business expenses. Applying the purpose test for subsidies and grants, the assistance was linked to capital infrastructure rather than revenue operations. On identical facts, the receipts had already been assessed as capital receipts in earlier scrutiny years, and in the absence of any material change, a contrary view for the year under review was unsustainable. The receipt was therefore not chargeable to tax, and the addition was deleted.</description>
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