PCIT v. Shantinath Detergents (P.) Ltd. [2024] 461 ITR 302 (Cal)(HC)

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Sales tax subsidy-Shown taxable in the return-CIT(A) is justified admitting the additional ground-Order of Tribunal is affirmed.[S.4, 139(5), 254((1)]

Held that when the subsidies received is held to be capital receipts and not an income, and hence not liable to tax, the Tribunal, in the exercise of its power under section 254 of the Act, was justified to uphold this claim even when no revised return under section 139(5) of the Act was filed before the Assessing Officer.(AY. 2009-10 to 2013-14  2015-16)