TaxTMI 
TaxTMI 
1982 (7) TMI 161
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.... of Madhya Pradesh was liable to be included in its total income. 2. The assessee is a co-operative society carrying on the business of banking. It received various amounts as subsidies from the government of Madhya Pradesh which were credited to its profit and loss account. It was claimed before the ITO that the above amounts did not form part of the assessee's income and were, therefore, not li....
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....e Registrar may, if he is satisfied that such an aid is necessary in the interest of the society, recommend to the State Government the grant of such aid. The State Government may thereupon grant such aid to the society as it may deem fit on such terms and conditions as may be prescribed." It was submitted before us that the assessee had received various subsidies in different years for specific ....
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....not be termed as a revenue receipt. It is clearly in the nature of a capital receipt, more so when it was given to the assessee for a specific purpose. The aid was also not related to the assessee's volume of business. We, therefore, agree with the finding of the Commissioner (Appeals) that the subsidy or donation, whatever it was, was not a receipt of revenue nature and was, therefore, rightly ex....