The Assessing Officer held that entire eligible credit of Rs.129-24 crores under the  Served from India Scheme to be receipt taxable as income. On appeal the CIT(A) held that  out of the total eligible credit the assessee had utilised sum of Rs.4.36 crores ad 6.44 crores against excise duty  and custom duty liabilities and restricted the addition to the sum utilised, i.e. Rs.10.80 crores. On appeal by the assessee and department, the Tribunal held that  Served from India Scheme credit is not in the nature of income. Served from India Scheme credit reduced the capital goods purchased by the assessee and when given to the assessee could be utilised only against purchase of capital goods and to be set off a portion of Excise duty and custom duty  and did not constitute taxable income as per section 2(24)(xviii) of the Act. Accordingly the appeal of the assessee was allowed and appeal of the Department was dismissed.  (AY. 2015-16)