Facts of the Case

The appellant-assesse, a private limited company was loss making Company, received subvention from its parent Company in Germany. As per assessing officer these subventions should be treated as revenue receipts.

Commissioner of Income tax & Income tax Appellate Tribunal reversed the said Findings of Assessing Officer whereas High court has resorted the view taken taken by the Assessing Officer. Aggrieved Assessee has filed appeal to the supreme Court.

Question

Whether the subvention was capital or revenue receipt?

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