Sahney Steel and Press Works Ltd. v. CIT

228 ITR 253Supreme Court of India1997#166 most cited

What is Sahney Steel and Press Works Ltd. v. CIT authority for?

A subsidy is treated as a revenue receipt if the assessee is free to use the money in its business as it likes and is not obligated to spend it for a specific capital purpose, such as acquiring assets or repaying loans.

429

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2007 to 2026.

Also referred to as

Sahney Steel and Press Works Ltd. v. CIT · subsidy revenue receipt · capital receipt · taxability of subsidies · Section 2(24)(xviii) · Section 37(1) · purpose of subsidy · obligation to spend · income tax treatment of subsidies

Sections most often in play

Section 143(3)Section 115JBSection 14ASection 2(24)(xviii)Section 37(1)Section 32Section 43(1)Section 147

Issues it is cited on

section 2(24)(xviii)section 43(1)section 40(a)(ii)book profitsdeduction under section 80iablock of assetssection 80hhcadditional depreciationwritten down valuesection 139(5)section 80hhsection 2(24)

Judgments citing Sahney Steel and Press Works Ltd. v. CIT

Housing & Urban Development Corporation Ltd, New Delhi vs. Addl. CIT, Range-4, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 1954/DEL/2018[2014-15]Status: DisposedITAT Delhi31 Jul 2025AY 2014-15

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…1954 & 2063/DEL/2018 [A.Y. 2014-15] ITA No. 7218 & 6829/DEL/2018 [A.Y. 2015-16] M/s Housing & Urban Dev. Corpn Ltd Vs.The Dy. C.I.T Circle – 11(2) Officer relying upon the judgment of the Hon'ble Supreme Court in the case of Sawhnay Steel and Press Works Ltd 228 ITR 253 and in the case of Ponni Sugar and Chemical Limited 306 ITR 392, held the premium as revenue in and nature and added back the same to the income of the assessee. Upon appeal by the assessee, the ld. CIT(A) upheld the addition made by the Assessing Officer. Now the Assessee is in appeal before us. 29. We have heard the rival submissions and have…

Addl. CIT, New Delhi vs. M/S. Hudco Ltd., New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 3704/DEL/2017[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…1954 & 2063/DEL/2018 [A.Y. 2014-15] ITA No. 7218 & 6829/DEL/2018 [A.Y. 2015-16] M/s Housing & Urban Dev. Corpn Ltd Vs.The Dy. C.I.T Circle – 11(2) Officer relying upon the judgment of the Hon'ble Supreme Court in the case of Sawhnay Steel and Press Works Ltd 228 ITR 253 and in the case of Ponni Sugar and Chemical Limited 306 ITR 392, held the premium as revenue in and nature and added back the same to the income of the assessee. Upon appeal by the assessee, the ld. CIT(A) upheld the addition made by the Assessing Officer. Now the Assessee is in appeal before us. 29. We have heard the rival submissions and have…

M/S. Housing & Urban Development Corporation Ltd., New Delhi vs. DCIT, New Delhi

The appeal of the assessee is partly allowed for statistical

ITA 3305/DEL/2017[2012-13]Status: DisposedITAT Delhi31 Jul 2025AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR

…1954 & 2063/DEL/2018 [A.Y. 2014-15] ITA No. 7218 & 6829/DEL/2018 [A.Y. 2015-16] M/s Housing & Urban Dev. Corpn Ltd Vs.The Dy. C.I.T Circle – 11(2) Officer relying upon the judgment of the Hon'ble Supreme Court in the case of Sawhnay Steel and Press Works Ltd 228 ITR 253 and in the case of Ponni Sugar and Chemical Limited 306 ITR 392, held the premium as revenue in and nature and added back the same to the income of the assessee. Upon appeal by the assessee, the ld. CIT(A) upheld the addition made by the Assessing Officer. Now the Assessee is in appeal before us. 29. We have heard the rival submissions and have…

Sylvan Greens Private Limited, Jaipur vs. Deputy Commissioner of Income Tax Circle 6, Jaipur

In the result, the appeal of the assessee is allowed

ITA 414/JPR/2025[2015-16]Status: DisposedITAT Jaipur25 Jul 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Smt. Neelam Bhala, AdvocateFor Respondent: Shri Gorav Avasthi, JCIT-DR
Section 142(1)Section 143(3)Section 147Section 148Section 250Section 801C

…is Court notices that the Punjab and Haryana High Court took into account the previous binding ruling of the Supreme Court in CIT v. Ponni Sugars & Chemicals Ltd. [2008] 174 Taxman 87/306 ITR 392 and Sahney Steel & Press Works Ltd. v. CIT [1997] 94 Taxman 368/228 ITR 253. In these circumstances, the Court is of the opinion that the amount was received as capital stream and therefore, not taxable. 7. A similar view was taken by the Calcutta High Court in CIT v. Gloster Jute Mills Ltd . [2018] 96 taxmann.com 303/257 Taxman 512/[2019] 416 ITR 458. 8. As far as the question with regard to Focus Marketing Scheme was c…

M/S Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 2539/DEL/2017[2005-06]Status: DisposedITAT Delhi16 Jul 2025AY 2005-06

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

For Appellant: Shri Ajay Vohra, Sr. A.RFor Respondent: Shri Bhopal Singh, Sr. D.R
Section 92C

…the assessee cannot claim a relief without filing the return of income under the provisions of section 139(1) or 139(5) of the Act. The ld. AO further dealt with the issue on merits and relied upon the judgement in the case of Sahney Steel Vs. CIT reported in 228 ITR 253(SC), and concluded that the sales tax incentives are revenue receipts and hence the same are liable to be taxed under the Income tax act. Thereafter, the AO has also referred to the other judgements and dismissed the contention of the assessee. It is pertinent to note here that the ld. AO after referring to the judgement in the case of Ponni Suga…

Gujarat Guardian Ltd., New Delhi vs. DCIT, New Delhi

ITA 159/DEL/2010[2003-04]Status: DisposedITAT Delhi16 Jul 2025AY 2003-04

Bench: Shri Prakash Chand Yadav & Shri Brajesh Kumar Singh

Section 92C

…the assessee cannot claim a relief without filing the return of income under the provisions of section 139(1) or 139(5) of the Act. The ld. AO further dealt with the issue on merits and relied upon the judgement in the case of Sahney Steel Vs. CIT reported in 228 ITR 253(SC), and concluded that the sales tax incentives are revenue receipts and hence the same are liable to be taxed under the Income tax act. Thereafter, the AO has also referred to the other judgements and dismissed the contention of the assessee. It is pertinent to note here that the ld. AO after referring to the judgement in the case of Ponni Suga…

M/S Chatta Sugar Co. Ltd, Mathura vs. A.C.I..T Circle-3, Mathura

In the result, the appeal of the assessee is allowed

ITA 129/AGR/2015[2009-10]Status: DisposedITAT Agra01 Jul 2025AY 2009-10

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2009-10]

Section 142(1)Section 143(3)Section 28Section 41(1)

…ein, it held that concession of purchase tax was in no way connected to expenditure in setting up the industry and such incentive was revenue receipt. Further, the Assessing Officer relied upon the decisions of Sahney Steel and Press Works Ltd. vs CIT (1997) 228 ITR 253 (SC) and the decision of Merino Ply and Chemicals Ltd. vs CIT (1994) 209 ITR 508 (Cal) and observed that in this case the grant received by the assessee was to discharge its trading liability and thus it constituted trading receipt and not capital receipts as claimed by the assessee. The AO held that the subject receipt was clearly taxable up 2…

Income Tax Officer, Ward-11(1), Pune vs. Maharashtra Cricket Association, Pune

In the result, the appeal of the Revenue is allowed for statistical

ITA 694/PUN/2023[2010-11]Status: DisposedITAT Pune09 Jun 2025AY 2010-11
For Appellant: Shri C.H. NaniwadekarFor Respondent: Shri Amol Khairnar
Section 10Section 11Section 12ASection 143(2)Section 2(15)

…characterized as falling in the revenue or capital stream, the objective for which it is given as well as the manner in which it is utilized has to be scrutinized This aspect has been highlighted in Sahney Steel & Press Works Lid. v. CIT [1997] 94 Тахтап 368/228 ITR 253/142 CTR 261 (SC)/1997 (Suppu) SCR 189 in the following terms: "It is not the source from which the amount is paid to the assessee which is determinative of the question whether the subsidy payments are of revenue or capital nature. The first proposition stated by Viscount Simon in Ostime case [28 TC 261: (1946) 1 All ER 668) is that if payments i…

Jindal Saw Ltd., New Delhi vs. ACIT, Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 504/DEL/2022[2014-15]Status: DisposedITAT Delhi04 Jun 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…y the purpose for which the subsidy is granted and not the form/mode/manner in which the subsidy is received/disbursed. The law in this regard is fairly well settled and reference may be made to the following decisions:  Sahney Steel and Press Works vs. CIT: 228 ITR 253 (SC)  CIT V. Ponni Sugar and Chemicals Limited: 306 ITR 392 (SC)  CIT vs. Chaphalkar Brothers: 400 ITR 279 (SC)  PCIT vs. Nitin Spinners Ltd [2021] 130 taxmann.com 402 (SC)  CIT vs. Shyam Lal Bansal [2011] 11 taxmann.com 369 (Punjab & Haryana) The purpose for which the incentives have been given, it is submitted, can be gauged from the object…

DCIT Circle-13(2), New Delhi vs. Jindal Saw Ltd., New Delhi

In the result, assessee’s appeal in ITA No

ITA 4760/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…y the purpose for which the subsidy is granted and not the form/mode/manner in which the subsidy is received/disbursed. The law in this regard is fairly well settled and reference may be made to the following decisions:  Sahney Steel and Press Works vs. CIT: 228 ITR 253 (SC)  CIT V. Ponni Sugar and Chemicals Limited: 306 ITR 392 (SC)  CIT vs. Chaphalkar Brothers: 400 ITR 279 (SC)  PCIT vs. Nitin Spinners Ltd [2021] 130 taxmann.com 402 (SC)  CIT vs. Shyam Lal Bansal [2011] 11 taxmann.com 369 (Punjab & Haryana) The purpose for which the incentives have been given, it is submitted, can be gauged from the object…

Jindal Saw Ltd., New Delhi vs. ACIT Circle-13(2), New Delhi

In the result, assessee’s appeal in ITA No

ITA 4693/DEL/2019[2015-16]Status: DisposedITAT Delhi04 Jun 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2011-12] Jindal Saw Ltd. Vs Dcit, 28, Najafgarh Road, Circle-13(2) New Delhi-110015. (Earlier Addl.Cit Range-4), Pan-Aabcs7280C C.R.Building, I.P.Estate, New Delhi-110002. Appellant Respondent [Assessment Year : 2011-12] Dcit, Vs Jindal Saw Ltd. Circle-13(2), (Formerly Known As M/S. Saw Pipes Room No.316A, Ltd.), 28, Najafgarh Road, C.R.Building, New Delhi-110015. New Delhi Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2014-15] Jindal Saw Ltd., Vs Acit, 28, Najafgarh Road, Shivaji Marg, Circle-13(2), New Delhi-110015. New Delhi. Pan-Aabcs7280C Appellant Respondent [Assessment Year : 2015-16] Jindal Saw Ltd. Vs Acit, 28, Najafgarh Road, Circle-13(2) P.O.Ramesh Nagar, C.R.Building, I.P.Estate, New Delhi-110015. New Delhi-110002. Pan-Aabcs7280C Appellant Respondent

Section 143(3)Section 234BSection 43B

…y the purpose for which the subsidy is granted and not the form/mode/manner in which the subsidy is received/disbursed. The law in this regard is fairly well settled and reference may be made to the following decisions:  Sahney Steel and Press Works vs. CIT: 228 ITR 253 (SC)  CIT V. Ponni Sugar and Chemicals Limited: 306 ITR 392 (SC)  CIT vs. Chaphalkar Brothers: 400 ITR 279 (SC)  PCIT vs. Nitin Spinners Ltd [2021] 130 taxmann.com 402 (SC)  CIT vs. Shyam Lal Bansal [2011] 11 taxmann.com 369 (Punjab & Haryana) The purpose for which the incentives have been given, it is submitted, can be gauged from the object…

Jindal Photo Ltd., New Delhi vs. ACIT, CC- 30, New Delhi

ITA 4492/DEL/2017[2014-15]Status: DisposedITAT Delhi21 May 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…

M/S Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

In the result, all the appeals of the assessee in ITA No

ITA 5451/DEL/2016[2013-14]Status: DisposedITAT Delhi21 May 2025AY 2013-14

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 153A

…he AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5257/DEL/2015[2012-13]Status: DisposedITAT Delhi21 May 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.10…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5256/DEL/2015[2011-12]Status: DisposedITAT Delhi21 May 2025AY 2011-12

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5255/DEL/2015[2010-11]Status: DisposedITAT Delhi21 May 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

In the result, all the appeals of the assessee in ITA No

ITA 5254/DEL/2015[2009-10]Status: DisposedITAT Delhi21 May 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 153A

…he AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5253/DEL/2015[2008-09]Status: DisposedITAT Delhi21 May 2025AY 2008-09

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5252/DEL/2015[2007-08]Status: DisposedITAT Delhi21 May 2025AY 2007-08

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…

M/S. Jindal Photo Ltd., New Delhi vs. ACIT, New Delhi

ITA 5251/DEL/2015[2006-07]Status: DisposedITAT Delhi21 May 2025AY 2006-07

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Rohit Jain, AdvFor Respondent: Ms. Baljeet Kaur, CIT-DR
Section 132Section 139(5)Section 153A

…the AO on grounds that claims are not admissible in the light of the decision in Goetze (supra); and on merits held that sales tax subsidy received qualified as revenue receipt and hence taxable relying on, relying on Sahney Steel & Press Works Ltd vs. CIT in 228 ITR 253 (SC). 14. The 3rd category involving AY 2012-13, the assessee in its original return filed under section 139(1) dated 24.09.2012 did not claim any exemption for sales tax subsidy as capital receipt. The assessee also did not claim any exemption for sales tax subsidy as capital receipt in its return filed in response to notice u/s 153A dated 30.1…