The Tribunal held that the subsidy was linked to reduction of price in manufacturing, and which can only be classified under revenue not capital. In this scheme, the ultimate object was to make available the required fertilisers and at appropriate price to the farmers, which can be achieved only by bringing new investments in the industry therefore, the adoption of purpose test by the CIT(A) is to be accepted in this case and the subsidy can be classified as capital in nature. It is opined that a receipt that is held to be a capital in nature and not chargeable to tax under the normal provisions of the Act hence the same lies outside the purview of MAT and is to be excluded while computing book profit. (AY. 2015-16)