2013 (3) TMI 175

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..... of grant in aid from the State Government. The assessee reflected the same as capital receipt, whereas it has been treated as to be revenue receipt. The issue, whether the amount of grant in aid is capital receipt or a revenue receipt, is a debatable issue. The findings returned in the judgment relied upon of CIT Versus ECS Ltd. [2010 (2) TMI 713 - DELHI HIGH COURT] is on fact of non-furnishing of .....

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..... ts and circumstances of case and under law has erred in not appreciating the penalty of Rs.10,50,00,000/- was levied on the basis of furnishing of inaccurate particulars of income by the assessee by treating the revenue receipt of Rs.2,15,00,000/- as capital receipt whereas the subsidy receipt is a revenue receipt and the addition has been confirmed by the Hon'ble ITAT, Amritsar Bench Amritsar? .....

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..... onvertible foreign exchange in India provided by it to its foreign clients. The Assessing Officer, however, was of the view that on correct interpretation under Section 80-O, deduction is restricted to the net income and, therefore, expenditure incurred in India for earning the foreign exchange had to be deducted. The Assessing Officer, therefore, wanted the assessee to furnish the details of expe .....

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