The assessee had received grant/financial assistance from the Government of India.  The assessee had recorded the same as capital receipt and not offered to tax which was accepted by the Department from AY 2006-07 till AY 2013-14.  However, for AY 2014-15 the Department in the assessment has considered the receipt as revenue in nature and made an addition on account of the same.  The Tribunal after going through the facts and circumstances of the case and relying on the decision of Apex Court in case of  CIT v.  Ponni Sugars & Chemicals Ltd.  (2008) 306 ITR 362 (SC) and in the case of CIT v.  Chaphalkar Brothers Pune (2018) 400 ITR 279  (SC)  held that grants given for specific purpose to be applied for capital outlays is capital in nature and not chargeable to tax.  Further the Tribunal, placing reliance on the decision of Radhasaomi Satsang v.  CIT (1992) 193 ITR 321) (SC) and  CIT v.  Neo Poly Packs (P) Ltd (2000  ) 245 ITR 492 (Delhi)  (HC) noted that the Apex Court has laid down the principle of rule of consistency.  Thereby in absence of any material change justifying the Revenue to take different stand view, the same view as accepted by earlier years should continue to prevail till there is some material change in facts. (AY. 2014-15)