High Court  held that the assessee availed exemption from payment of tax under exemption certificate issued under section 4A of U.P. Trade Tax Act, 1948 on turnover of sales and claimed amount representing tax exemption component as capital receipt, since section 4A clearly indicated that exemption from tax on turnover of sales was not a subsidy granted by Government, aforesaid amount of tax component was a revenue receipt in hands of assessee and it could not be treated as capital receipt.  Whether in view of fact that issue regarding exemption granted under U.P. Trade Tax, 1948, and effect thereof was pending consideration before this Court in Tata Steel BSL Ltd. v. CIT [SLP (C) No(s). 30728-30732 of 2017] notice was to be issued in SLP filed by assessee against impugned order as well as on application for stay.