Subsidy received by assessee, engaged in manufacturing of extra neutral alcohol from grain, from State Government to encourage investments in grain based distilleries in backward regions of State, was a capital receipt. Subsidy received is not liable to be reduced from cost of assets for purpose of depreciation in year under consideration in view of proviso to Explanation 10 to section 43(1). Amendment to section 2(24) by inserting clause (xviii) by Finance Act, 2015 with effect from 1-4-2016 providing that even if a subsidy is given to attract industrial investment or expansion, which is otherwise a capital receipt under pre-amendment era, shall be treated as income chargeable to tax, is prospective in nature. (AY. 2011-12)