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“Section 2(24)(xviii)”

Section References (mined)Section 2Section 2(24)(xviii)99 judgments

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3991/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

Rs.5,15,25,900/- claimed as capital receipt exempt u/s 10 of the Act is taxed as revenue receipt in view of section 2(24)(xviii) of the Act and accordingly added to the income of assessee.” 14.3. Coordinate Bench considered the amendment brought to section 2(24)(xviii) which ... separate independent words and not defined under the Act. It concluded that the word “exemption” is not included in the ambit of section 2(24)(xviii) though, it specifically includes the words, ‘subsidy’, ‘grant’, ‘cash incentive’, ‘duty drawback’, ‘waiver’, ‘concession’ and ‘reimbursement’, and hence in absence of the inclusion

DCIT, CIRCLE-3(4), MUMBAI, MUMBAI vs. GLENMARK PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue for Assessment Year 2016-17

ITA 3971/MUM/2025[2015-16]Status: DisposedITAT Mumbai12 Mar 2026AY 2015-16

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Vijay Mehta, CAFor Respondent: Ms. Neena Jeph, CIT DR
Section 143(3)Section 35Section 41(1)Section 801C

Rs.5,15,25,900/- claimed as capital receipt exempt u/s 10 of the Act is taxed as revenue receipt in view of section 2(24)(xviii) of the Act and accordingly added to the income of assessee.” 14.3. Coordinate Bench considered the amendment brought to section 2(24)(xviii) which ... separate independent words and not defined under the Act. It concluded that the word “exemption” is not included in the ambit of section 2(24)(xviii) though, it specifically includes the words, ‘subsidy’, ‘grant’, ‘cash incentive’, ‘duty drawback’, ‘waiver’, ‘concession’ and ‘reimbursement’, and hence in absence of the inclusion

VALUELABS LLP,HYDERABAD vs. DCIT., CENTRAL CIRCLE 8(1), HYDERABAD

In the result, we uphold the order passed by the CIT(A) and\ndismiss the assessee's appeal

ITA 1609/HYD/2025[2020-21]Status: DisposedITAT Hyderabad06 Mar 2026AY 2020-21
For Appellant: \nShri P. Murali Mohan, CAFor Respondent: \nMs. U. Mini Chandran
Section 115BSection 143(3)Section 2(24)(xviii)Section 250Section 80

that the\nincome derived from the sale of RECs does not form part of 'business\nincome within the meaning of the proviso to Section 2(24)(xviii) of the\nAct, and therefore, the same cannot be taxed as business income at\nthe normal rate.\n6.\nThe Ld. CIT(A) erred

DCIT, CIRCLE-7(1), KOLKATA, KOLKATA vs. WEST BENGAL INDUSTRIAL DEVELOPMENT CORPORATION LIMITED, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 748/KOL/2025[2015-2016]Status: DisposedITAT Kolkata12 Feb 2026AY 2015-2016
Section 115JSection 143(2)Section 250Section 36(1)(viia)

grant/subsidy from government is now\ncovered by section 145B(3) which provides that income mentioned in section\n2(24)(xviii) is taxable. And section 2(24)(xviii) makes grants from government\ntaxable subject two exclusions. The relevant provisions are reproduced below:\nTaxability of certain income.\n145B. (1) Notwithstanding anything ... corpus\nof a trust or institution established by the Central Government or a State\nGovernment, as the case may be;\n6.4 However section 2(24)(xviii) was introduced only with effect from\n01.04.2016 (AY 2016-17). Therefore in the year this order pertains to is not\ncovered by this section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 7(1), KOLKATA, AAYAKAR BHAWAN, KOLKATA vs. WEST BENGAL INDUSTRIAL DEVELOPMENT CORPORATION LIMITED, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 623/KOL/2025[2015-2016]Status: DisposedITAT Kolkata12 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita No.623 & 748/Kol/2025 (Assessment Year: 2015-16) Dcit, Circle-7(1), Kolkata………...……………..……….……….……….……Appellant Vs. West Bengal Industrial Development Corporation Limited......……...…..…..Respondent 23, A N Thakur Sarani, Circus Avenue, Kol - 700017.. [Pan: Aaacw3043Q] Appearances By: Shri B R Dutta, Fca, Appeared On Behalf Of The Appellant. Shri Sanat Kr. Raha, Cit- Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 21, 2026 Date Of Pronouncing The Order : February 12, 2026 Order Per Pradip Kumar Choubey: Both The Present Appeals Have Been Preferred By The Assessee Against An Order Dated 09.08.2024 Of The Nfac, Delhi [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). Since Both The Appeals Relate To The Same Assessee & Arise From Same Appellate Order, Therefore, These Appeals Were Heard Together & We Are Going To Dispose Of These Appeals By Passing A Consolidated Order. 2. Ita No.623 & 748/Kol/2025 Filed By The Revenue With A Delay Of 139 & 159 Days Respectively & The Revenue Has Filed Separate Petitions For Condonation Of The Delays. After Going Over The Said Petitions, We Find Sufficient Reasons Behind Such Delays & Consequently, The Delays In Filing Both The Appeal Are Hereby Condoned & We Proceed To Dispose Of The Appeals On Merits.

Section 115JSection 143(2)Section 250Section 36(1)(viia)

grant was in the nature of a capital receipt. We find that the ld. CIT(A) has considered the section 145B(3) and section 2(24)(xviii) and also decision of Hon’ble Supreme Court. Going over the above discussion, we do not find any merit in the appeal

M/S. HYUNDAI MOTOR INDIA LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

ITA 434/CHNY/2025[2012-13]Status: DisposedITAT Chennai11 Feb 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. Sriram Seshadri, C.AFor Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 143(3)Section 254Section 263Section 43(1)

decision of the this Tribunal to the treatment of the same incentive in the Appellant’s own case, post amendment to Section 2(24)(xviii) of the Act, i.e, from AY 2016-17, wherein the AO and this Tribunal has treated the said subsidy as taxable under the Act, which ... applicable to the facts of the assessee’s case. In this connection, the Appellant reproduces the provisions of Section 2(24)(xviii) of the Act: :-14-: ITA. No:434/Chny/2025 “(xviii) assistance in the form of a subsidy or grant or cash incentive or duty drawback or waiver or concession

GUJARAT URBAN DEVELOPMENT CO. LTD.,GANDHINAGAR vs. THE DY.CIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, both the appeals of the assessee stand allowed

ITA 2158/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Gupta1. आयकर अपील सं /Ita No.2157/Ahd/2025 2. आयकर अपील सं /Ita No.2158/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Gujarat Urban Development The Dy.Cit, बनाम/ Co.Ltd. Gandhinagar Circle V/S. Karmayogi Bhavan It Office Block-1, Udhyog Bhavan B 1 Wing, Ground Floor Sector-11 Sector-10A Gandhinagar – 382 010 Gandhinagar – 382 010 "थायी लेखा सं./Pan: Aabcg 1330 R (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ars Revenue By : Shri Alpesh Parmar, Cit-Dr & Shri Arvind R. Kumbhare Sr.Dr सुनवाई की तारीख/Date Of Hearing : 21/012026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri S.N. Soparkar, Sr. Advocate and Ms. Ukti Shah, ARsFor Respondent: Shri Alpesh Parmar, CIT-DR and Shri Arvind R. Kumbhare Sr.DR
Section 234BSection 250Section 270A

leave to the competent authority to look into. 4.5. At this stage, the Ld. DR has pointed out to the provisions of section 2(24)(xviii) to submit that w.e.f. AY 2016-17 any assistance in the form of ‘subsidy’, or grant, or cash incentive, or duty draw back ... reimbursement by the Central or State Government, hence cannot be treated as income of the assessee. Therefore, in our view, the provisions of section 2(24)(xviii) are not attracted in this case to treat the ‘advance’ shown in the books of accounts out of the IDI received in past

GUJARAT URBAN DEVELOPMENT CO. LTD.,GANDHINAGAR vs. THE DY.CIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, both the appeals of the assessee stand allowed

ITA 2157/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Gupta1. आयकर अपील सं /Ita No.2157/Ahd/2025 2. आयकर अपील सं /Ita No.2158/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Gujarat Urban Development The Dy.Cit, बनाम/ Co.Ltd. Gandhinagar Circle V/S. Karmayogi Bhavan It Office Block-1, Udhyog Bhavan B 1 Wing, Ground Floor Sector-11 Sector-10A Gandhinagar – 382 010 Gandhinagar – 382 010 "थायी लेखा सं./Pan: Aabcg 1330 R (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ars Revenue By : Shri Alpesh Parmar, Cit-Dr & Shri Arvind R. Kumbhare Sr.Dr सुनवाई की तारीख/Date Of Hearing : 21/012026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri S.N. Soparkar, Sr. Advocate and Ms. Ukti Shah, ARsFor Respondent: Shri Alpesh Parmar, CIT-DR and Shri Arvind R. Kumbhare Sr.DR
Section 234BSection 250Section 270A

leave to the competent authority to look into. 4.5. At this stage, the Ld. DR has pointed out to the provisions of section 2(24)(xviii) to submit that w.e.f. AY 2016-17 any assistance in the form of ‘subsidy’, or grant, or cash incentive, or duty draw back ... reimbursement by the Central or State Government, hence cannot be treated as income of the assessee. Therefore, in our view, the provisions of section 2(24)(xviii) are not attracted in this case to treat the ‘advance’ shown in the books of accounts out of the IDI received in past

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

ITA 2174/CHNY/2024[2017-18]Status: DisposedITAT Chennai02 Jan 2026AY 2017-18
Section 10(39)Section 115JSection 14A

Section 115JB of the Income Tax Act", "Section 36(1)(iii) of the Income Tax Act", "Section 43B of the Income Tax Act", "Section 2(24)(xviii) of the Income Tax Act", "Section 28 of the Income Tax Act", "Section 80IA of the Income Tax Act", "Section

MAHARASHTRA AIRPORT DEVELOPMENT COMPANY LIMITED,MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, DELHI, DELHI

In the result, the appeal by the assessee is partly allowed

ITA 1366/MUM/2024[2021-22]Status: DisposedITAT Mumbai31 Dec 2025AY 2021-22

Bench: Shri Sandeep Singh Karhailshri Makarand Vasant Mahadeokarmaharashtra Airport Development Company World Trade Centre, Tower-1, 8Th Floor, Cuffe Parade, Mumbai - 400005 ............... Appellant Pan: Aadcm9623M

For Appellant: Shri Rushab MehtaFor Respondent: Shri Vivek Perampurna, CIT-DR
Section 143(3)Section 250Section 57

Government of Maharashtra towards Land acquisition, rehabilitation, infrastructural development, etc. amounting to Rs. 1,74,03,00,000/- by invoking provisions of Section 2(24)(xviii) of the Act without appreciating the assessee being an arm of the State and all the explanations and documents placed on record ... received by the assessee is of a revenue nature. In this regard, the AO also placed reliance on the provisions of section 2(24)(xviii) of the Act, whereby with effect from 2016-17, all the assistance, grants, whatever name called, received from the Central Government, State Government

JCIT CENT. CIR. - 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

The appeal is allowed

ITA 1561/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar / Ms SukanyaFor Respondent: Shri Arun Kanti Datta, CIT-DR
Section 153CSection 250Section 43BSection 80I

been granted. In other words, one has to apply the purpose test. 31.1 It has been noted that the amendment made in section 2(24)(xviii) of the Act is effective from A.Y. 2016-17 and this indicates that the legislature has decided that the subsidy is taxable income from

GRASIM INDUSTRIES LTD,MUMBAI vs. DCIT CENT. CIR. - 1(4), MUMBAI

The appeal is allowed

ITA 1056/MUM/2018[2011-12]Status: DisposedITAT Mumbai31 Dec 2025AY 2011-12
Section 153CSection 250Section 43BSection 80I

been granted. In other\nwords, one has to apply the purpose test.\n31.1 It has been noted that the amendment made in Section 2(24)(xviii) of the Act is\neffective from A.Y. 2016-17 and this indicates that the legislature has decided that\nthe subsidy is taxable income from

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 157/PUN/2025[2020-21]Status: DisposedITAT Pune22 Dec 2025AY 2020-21
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

appeal raised by the assessee are allowed.\n\n10.\nWe further note that an amendment has been brought in\nfrom 01.04.2016 inserting section 2(24)(xviii) of the Act which\nreads as under :\n\n“2(24)xviii) : Assistance in the form of a subsidy or grant or cash\nincentive ... Whether such treatment given by the\nassessee is correct or not needs to be examined.\n\n13. We note that post amendment in section 2(24)(xviii) of the\nAct, the subsidy is required to be treated as income for the\nyear other than the subsidy or grant which

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 156/PUN/2025[2018-19]Status: DisposedITAT Pune22 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

referred to plethora of decisions in the assessment order. It has been contended by the assessee that post amendment in section 2(24)(xviii) inserted by Finance Act, 2015 effective from 01.04.2016 assessee in accordance with the provisions of Explanation 10 to clause (1) of section ... case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. ITO WARD 6(1), PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 155/PUN/2025[2017-198]Status: DisposedITAT Pune22 Dec 2025AY 2017-198
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

Grounds of appeal raised by the assessee are allowed.\n10. We further note that an amendment has been brought in\nfrom 01.04.2016 inserting section 2(24)(xviii) of the Act which\nreads as under :\n“2(24)xviii) : Assistance in the form of a subsidy or grant or cash\nincentive ... reduced. Whether such treatment given by the\nassessee is correct or not needs to be examined.\n13. We note that post amendment in section 2(24)(xviii) of the\nAct, the subsidy is required to be treated as income for the\nyear other than the subsidy or grant which

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD,PUNE vs. NATIONAL FACELESS APPEAL CENTRE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 154/PUN/2025[2016-17]Status: DisposedITAT Pune22 Dec 2025AY 2016-17

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

referred to plethora of decisions in the assessment order. It has been contended by the assessee that post amendment in section 2(24)(xviii) inserted by Finance Act, 2015 effective from 01.04.2016 assessee in accordance with the provisions of Explanation 10 to clause (1) of section ... case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot

SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD.,PUNE vs. ACIT, CIRCLE-5, PUNE, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1423/PUN/2025[2019-20]Status: DisposedITAT Pune22 Dec 2025AY 2019-20

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

referred to plethora of decisions in the assessment order. It has been contended by the assessee that post amendment in section 2(24)(xviii) inserted by Finance Act, 2015 effective from 01.04.2016 assessee in accordance with the provisions of Explanation 10 to clause (1) of section ... case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot

DY. COMMISSIONER OF INCOME-TAX, CIRCLE-5, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PVT. LTD., PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 114/PUN/2025[2020]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

referred to plethora of decisions in the assessment order. It has been contended by the assessee that post amendment in section 2(24)(xviii) inserted by Finance Act, 2015 effective from 01.04.2016 assessee in accordance with the provisions of Explanation 10 to clause (1) of section ... case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot

ACIT, CIRCLE-5, PUNE, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos. 154 to 156/PUN/2025 filed by the assessee are partly allowed for statistical purposes, ITA

ITA 1844/PUN/2024[2019]Status: DisposedITAT Pune22 Dec 2025

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.154 To 156/Pun/2025 Assessment Years : 2016-17 To 2018-19

For Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 2(24)(xviii)Section 43

referred to plethora of decisions in the assessment order. It has been contended by the assessee that post amendment in section 2(24)(xviii) inserted by Finance Act, 2015 effective from 01.04.2016 assessee in accordance with the provisions of Explanation 10 to clause (1) of section ... case of CIT Vs. Ponny Sugars and Chemicals Ltd. 306 ITR 392. Ld.CIT(A) has also discussed the amendment in section 2(24)(xviii) effective from 01.04.2016 and has held that since the purpose of the subsidy is not towards acquiring of any new fixed assets therefore such subsidy cannot

ACIT, PUNE vs. SHRINIWAS ENGINEERING AUTO COMPONENTS PRIVATE LIMITED, PUNE

In the result, ITA Nos.154 to 156/PUN/2025 filed by the\nassessee are partly allowed for statistical purposes, ITA\nNo

ITA 1843/PUN/2024[2018]Status: DisposedITAT Pune22 Dec 2025
Section 2(24)(xviii)Section 43

Grounds of appeal raised by the assessee are allowed.\n10. We further note that an amendment has been brought in\nfrom 01.04.2016 inserting section 2(24)(xviii) of the Act which\nreads as under :\n“2(24)xviii) : Assistance in the form of a subsidy or grant or cash\nincentive ... reduced. Whether such treatment given by the\nassessee is correct or not needs to be examined.\n13. We note that post amendment in section 2(24)(xviii) of the\nAct, the subsidy is required to be treated as income for the\nyear other than the subsidy or grant which

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