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    <title>2021 (4) TMI 1153 - ITAT AHMEDABAD</title>
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    <description>Interest subsidy under the Technology Upgradation Fund Scheme was treated as a capital receipt because the scheme&#039;s purpose was industrial upgradation rather than meeting trading operations. The Tribunal noted that the omitted grounds were already covered by the assessee&#039;s earlier year decision and, on that basis, accepted the subsidy as outside the tax net for the relevant year. It also referred to the later insertion of section 2(24)(xviii) as consistent with that view. However, because the factual quantum and supporting documents needed verification, the matter was restored to the Assessing Officer for verification and consequential relief.</description>
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      <description>Interest subsidy under the Technology Upgradation Fund Scheme was treated as a capital receipt because the scheme&#039;s purpose was industrial upgradation rather than meeting trading operations. The Tribunal noted that the omitted grounds were already covered by the assessee&#039;s earlier year decision and, on that basis, accepted the subsidy as outside the tax net for the relevant year. It also referred to the later insertion of section 2(24)(xviii) as consistent with that view. However, because the factual quantum and supporting documents needed verification, the matter was restored to the Assessing Officer for verification and consequential relief.</description>
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