Assessee-company is  a 100 per cent subsidiary company of H, a wholly owned Government enterprise.  Government sanctioned certain amount to assessee towards setting up of Integrated Vaccine Complex. Assessee parked certain amounts out of said funds which were not immediately required for construction, in banks and received interest from such short-term deposits. Interest income was set off against expenditure incurred for construction of Integrated Vaccine Complex. Assessing Officer treated interest received as income from other sources.  It  that in communication from Government of India to assessee it is categorically mandated that funds and income earned out of funds provided by Government was to be utilised only for purpose for which they were released. It is also clarified that any interest income from said funds consequent on bank deposits, would also be utilised only for purpose of project. Since deposits and income were inextricably linked with setting up of project, interest income on short-term deposits of funds infused by Government is  in nature of capital receipt and not revenue receipt.  (AY. 2013-14, 2014-15 and 2015-16)