The assessee, engaged in the business of generation and distribution of electricity, earned income from trial runs of its broadband project and from sale of scrap generated prior to installation of the project. The receipts were treated as capital work-in-progress and were not offered to tax. The Assessing Officer assessed the receipts as revenue income. The Tribunal held that the broadband unit was still under installation and the receipts from trial runs and sale of scrap were intrinsically connected with the setting up of the project and, therefore, constituted capital receipts. Dismissing the Revenue’s appeal, the Bombay High Court held that receipts generated before commencement of business, which are inextricably connected with the setting up of a capital asset, reduce the cost of construction and are capital in nature. The Tribunal had correctly applied the ratio of CIT v. Bokaro Steel Ltd. (1999 ) 236 ITR 315 (SC). No substantial question of law arose. (ITXA No. 21 of 2020, dated 23-07-2026, (A.Y. 2003-04. )