Loan given by Government of Karnataka was subsequently  waived. The AO assessed the waiver of loan as value of benefit or perquisite assessable u/s 28(iv) of the Act .CIT (A) deleted the addition. On appeal by the revenue the Tribunal held that   the AO had correctly made the addition considering the waiver of loan as revenue receipt of the assessee . On appeal High Court held that  waiver of loan cannot be assessed as benefit or perquisite . Followed  CIT v .Mahindra and Mahindra Ltd (2018) 404 ITR 1 (SC)  ,distinguished ,   Protos Engineering Company P. Ltd   v  CIT, ( 1995 ) 211 ITR 919 (Bom) (HC) is held to be not good law .  (ITA No 201 of (AY .1984 -85)