The Assessee Company engaged in diverse business had received subsidy under the technology up gradation fund scheme, claimed subsidy as capital receipt. The department treated subsidy as revenue in nature.  Held that the subsidy received by Assessee Company under the technology up-gradation fund scheme was a capital receipt. Interest subsidy received under the technology up-gradation fund scheme, though  net off against the interest expenditure in the books of account is still capital in nature and therefore not taxable. (AY.2009-10)