Subsidy Receipts Misclassified as Revenue: Section 2(24)(xviii) Inapplicable Due to Assessment Year Preceding Proviso Insertion.

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....Nature/Character of receipt - subsidy receipt - revenue or capital receipt - Applicability of purpose test - section 2(24)(xviii) would be attracted, in principle, but would not apply as the assessment year under consideration is prior to the insertion of the proviso. It is, therefore, held that the authorities below were not justified in treating the amount of subsidy as a ‘Revenue’ receipt chargeable to tax. - AT....