https://www.taxtmi.com/caselaws?id=764027 ITAT Mumbai dismissed revenue's appeal regarding treatment of fertilizer subsidy as capital receipt. The assessee filed rectification application under section 154 after SC decision on subsidy allowability, which AO rejected. CIT(A) held fertilizer subsidy received under NBS policy constituted capital receipt, not taxable income. ITAT followed its earlier decision for AY 2015-16 favoring assessee, noting the scheme aimed to attract industry investment and new players. The subsidy mechanism ultimately ensured fertilizer availability at appropriate prices to farmers through new investments, supporting capital receipt treatment. en-us Wed, 06 Nov 2024 00:00:00 +0530 Thu, 02 Jan 2025 08:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764027 ITAT Mumbai dismissed revenue's appeal regarding treatment of fertilizer subsidy as capital receipt. The assessee filed rectification application under section 154 after SC decision on subsidy allowability, which AO rejected. CIT(A) held fertilizer subsidy received under NBS policy constituted capital receipt, not taxable income. ITAT followed its earlier decision for AY 2015-16 favoring assessee, noting the scheme aimed to attract industry investment and new players. The subsidy mechanism ultimately ensured fertilizer availability at appropriate prices to farmers through new investments, supporting capital receipt treatment. Case-Laws Income Tax Wed, 06 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764027