Bench: Shri A.T. Varkey & Shri Manish Borad
115J for the purpose of imposing a tax thereon. 21. After going through the above referred judgments and decisions and on examining the facts of the instant case, we find that the excise duty exemption has been admittedly the capital receipt and the finding of the ld. CIT(Appeals) that the excise duty exemption is not liable to be taxed