The Government of Maharashtra to achieve the dispersal of industries outside the Mumbai-Thane-Pune belt and to incentivise the setting up of new and expanded units in underdeveloped and developing areas, had, in 1964, forged a scheme titled “Package Scheme of Incentives”. The Package Scheme of Incentives introduced in 1964 underwent changes from time to time. The 1993 Scheme was rooted in the Package Scheme of Incentives put in place by the Government of Maharashtra, as indicated above, in 1964. The 1993 Scheme was forged to achieve three broad objectives : (i) first, to disperse industries outside the now Mumbai-Thane-Pune belt and to attract new and expanded units to developing and underdeveloped areas of the State ; (ii) second, to rationalise incentives accorded by intensifying and accelerating the dispersal of units from developed to underdeveloped and developing areas ; and (iii) third, the development of underdeveloped regions of the State, particularly those which were at some distance from the Mumbai-Thane-Pune belt. Thus, the central theme, object and purpose of the 1993 Scheme was to industrialise underdeveloped and developing areas which fell outside the now Mumbai-Thane-Pune belt by incentivising the setting up of new and expanded units. The common thread running through various incentives provided under the scheme was the setting up of new units or large-scale investment in fixed capital. The fact that the eligibility certificate was to be issued by the agency implementing the scheme after the commencement of commercial production by the eligible unit had been incorporated in the 1993 Scheme to ensure that the object and the purpose of the 1993 Scheme, which was to industrialise underdeveloped and developing areas was fulfilled.  Dismissing the appeal of the Revenue the Court held  that the assessee was entitled to avail of sales-tax subsidy and incentives under two eligibility certificates dated December 13, 1994 and October 15, 1996 (as amended) for 14 years and 13 years and 11 months, respectively, subject to a maximum entitlement of 110 per cent. of the capital investment made in setting up of the industrial units. A perusal of the eligibility certificate dated December 13, 1994 would show that it was issued for setting up a “new unit”, while the eligibility certificate dated October 15, 1996 was given to a “pioneer unit” which had undertaken expansion. The sales tax subsidy or incentive received by the assessee under 1993 Scheme was a capital receipt. (AY.1997-98, 2005-06, 2006-07, 2008-09, 2013-14, 2014-15)