Assessee received subsidies from Govt. of West Bengal under West Bengal Incentive Scheme, 2004 for industrial projects. The Assessing Officer held that subsidy is revenue receipts. On appeal the Tribunal treated subsidy as capital in nature, intended for industrialization, and not taxable as revenue receipts. Tribunal also held that  as per provisions of Industrial Promotion Assistance Scheme as framed by State of West Bengal, receipt of subsidies was clearly linked to a total investment exceeding INR 25,00,00,000 being made and would have become payable on commencement of commercial production. Affirming the order of the Tribunal the Court held that since, subsidy being clearly linked to establishment of new units, it would be treated as capital in nature.  As regards the issue of Advertisement, Marketing and Promotion (“ AMP”), the appeals would be re-notified, since both sides seek an opportunity to address submissions in greater detail.