2024 (4) TMI 1176

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....tion 14A(2) of the Income Tax Act, 1961["Act"], interest on receivables and ICC sponsorship are concerned, concededly stand concluded by findings of fact as recorded by the Income Tax Appellate Tribunal ["ITAT"] and clearly do not give rise to any substantial question of law. 2. Insofar as the issue of pricing support is concerned, we note that the ITAT has essentially taken into consideration its own decision rendered inter partes for Assessment Year ["AY"] 2006-07. We are further informed that the appeal with respect to AY 2006-07 has come to be dismissed by this Court in terms of the orders passed in ITA 474/2017. 3. That only leaves us to deal with the two surviving issues, namely of Advertisement, Marketing and Promotion ["AMP"] and ....

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....etting up and expansion of projects/industries and was not available to the existing industries unless they undertook substantial expansion. The Hon'ble Supreme Court in the case of CIT VS. Ponni Sugar and Commercial Ltd. (supra) observed that character of the receivables in the hands of the assessee had to be determined with respect to the purpose for which subsidy was given. The purpose for which subsidy is given assumes more significance rather than the manner in which it has been given. Here in this case also the subsidy was given by the Government of West Bengal for the purpose of industrialization of the State which was available only to new units or to existing units which were initiating substantial expansion. Under the Scheme I....