(1.) THE Revenue seeks to appeal against the impugned order of the Income Tax Appellate Tribunal (hereinafter called ,,ITAT) in Income Tax Appeal No.1405/Del/2010 dated 14.10.2011.
(2.) THE substantial question sought to be urged by the Revenue is as follows: - "Whether the amount of Rs.11,22,38,874/-, infused by BHW Holding AG, Germany to the assessee by way of subvention assistance, is taxable as a revenue receipt and therefore falls within the definition of ,,income under Section 2 (24) of the Income Tax Act, 1961."
(3.) THE ITAT rejected the Revenues appeal, inter alia, holding that: -