https://www.taxtmi.com/caselaws?id=792711 Settlement under the Direct Tax Vivad Se Vishwas Scheme did not erase the reassessment order for collateral purposes, so limitation for rectification under section 154 ran from the reassessment order and the application was within time. Applying the purpose test, fertilizer subsidy under the Nutrient Based Subsidy Policy was treated as a capital receipt because the scheme promoted long-term industry objectives rather than meeting trading or operating costs. As a capital receipt, it was not chargeable to tax and was to be excluded while computing book profit under section 115JB. en-us Wed, 27 May 2026 00:00:00 +0530 Tue, 02 Jun 2026 08:47:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792711 Settlement under the Direct Tax Vivad Se Vishwas Scheme did not erase the reassessment order for collateral purposes, so limitation for rectification under section 154 ran from the reassessment order and the application was within time. Applying the purpose test, fertilizer subsidy under the Nutrient Based Subsidy Policy was treated as a capital receipt because the scheme promoted long-term industry objectives rather than meeting trading or operating costs. As a capital receipt, it was not chargeable to tax and was to be excluded while computing book profit under section 115JB. Case-Laws Income Tax Wed, 27 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792711