Held that  the proceeds realized by the assessee on sale of certified emission reduction credit, which the assessee had earned on the clean development mechanism in its wind energy operations, was a capital receipt and not taxable. The sale of carbon credits was to be considered a capital receipt and not liable for tax under any head of income and that there was no cost of acquisition or cost of production to get entitlement for the carbon credits.  S. P. Spinning Mills (P) Ltd. v. ACIT [2021] 433 ITR 61 (Mad)(HC) followed. Court also held that the technology upgradation fund subsidy and the compensation receivable on non-performance of the energy generation were capital receipts and not liable for tax under any head of income. (AY. 2011-12)