The assessee has shown the subsidy as capital receipt in the return of Income . The Assessing Officer accepted the claim of the assessee  without examining the subsidy scheme. Commissioner passed the revision order after examining  the   scheme and the order was set aside for  re adjudication .    On appeal the Tribunal quashed the order of the Commissioner  on the ground that subsidy being capital in nature , revision was bad in law . On appeal the High Court  PCIT v. L.G. Electronics India ( P) Ltd  ( 2022 ) 134 taxmann.com 329 ( Delhi )(HC) ,   set aside the order of the Tribunal and held that the AO’s decision accepting the assessee’s returns on the point upon the assessee’s explanation without recording any reason , given the complex nature of subsidy , was ex facie erroneous .   The High Court directed the Assessing Officer to pass a fresh order upon his independent analysis as to whether the amount received by way of subsidy is capital or  revenue nature . On appeal SLP filed by the assessee was dismissed and the order of High Court is affirmed . ( AY. 2008 -09 )