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    <title>2025 (12) TMI 1091 - ITAT PUNE</title>
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    <description>The dominant issue was whether the subsidy received under the State incentive scheme was a capital receipt or a revenue receipt, and whether it required reduction from actual cost under Explanation 10 to s. 43(1). The Tribunal held that Explanation 10 applies only where the subsidy is relatable to acquisition of a fixed asset; since the subsidy was not linked to any specific fixed asset, Explanation 10 and its proviso were inapplicable. Consequently, the subsidy was characterized as a capital receipt, the contrary appellate finding was reversed, and the assessee&#039;s appeal was allowed.</description>
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      <title>2025 (12) TMI 1091 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=783551</link>
      <description>The dominant issue was whether the subsidy received under the State incentive scheme was a capital receipt or a revenue receipt, and whether it required reduction from actual cost under Explanation 10 to s. 43(1). The Tribunal held that Explanation 10 applies only where the subsidy is relatable to acquisition of a fixed asset; since the subsidy was not linked to any specific fixed asset, Explanation 10 and its proviso were inapplicable. Consequently, the subsidy was characterized as a capital receipt, the contrary appellate finding was reversed, and the assessee&#039;s appeal was allowed.</description>
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