https://www.taxtmi.com/caselaws?id=464193 ITAT MUMBAI held that admitting additional grounds raised by letter was improper per the SC precedent, but where an earlier Bench admitted the grounds and the AO had given effect, the revenue could not re-open them. Fertilizer subsidy under the NBS and SHIS incentives were held to be capital receipts, not taxable for the relevant years, since the Finance Act amendment w.e.f. 01-04-2016 is prospective and inapplicable retroactively. Consequently such capital receipts are excluded from book profit for computing tax under section 115JB, and the revenue's appeals on these issues were dismissed. en-us Fri, 04 Apr 2025 00:00:00 +0530 Thu, 09 Oct 2025 20:48:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464193 ITAT MUMBAI held that admitting additional grounds raised by letter was improper per the SC precedent, but where an earlier Bench admitted the grounds and the AO had given effect, the revenue could not re-open them. Fertilizer subsidy under the NBS and SHIS incentives were held to be capital receipts, not taxable for the relevant years, since the Finance Act amendment w.e.f. 01-04-2016 is prospective and inapplicable retroactively. Consequently such capital receipts are excluded from book profit for computing tax under section 115JB, and the revenue's appeals on these issues were dismissed. Case-Laws Income Tax Fri, 04 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464193