The Tribunal held that the purpose of  giving the incentive in the form of  interest subsidy under the technology upgradation fund scheme was to encourage capital investment by the   eligible unit in  the form of  specified machinery in order to induct State-of -the-Art or  Near-State-of -the-Art Technology or  at  least a significant step up from the present technology level to  a substantially higher one. The amount of  interest subsidy received by the assessee was a receipt of  capital nature. The Assessing Officer was to verify the issue of  utilisation of  the subsidy  if the purpose of meeting the interest Liability on loans and advances taken by it to set up its plant and machinery, the subsidy incentive could be considered as a capital receipt not chargeable to tax ,  otherwise, it  had to be treated as a revenue receipt.( AY.2008-09)