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.

1. That on the facts and the circumstances of the case and in law, the Ld. CIT (A) erred in not appreciating that the grant received by the State Government was income of the assessee and therefore it is taxable under the Income-tax Act, 1961. 2. That the Ld. CIT (A) has erred in holding that the orders