( 1 ) LEAVE granted. ( 2 ) LOOKING to the facts, circumstances, and the nature of the subsidy, which is a power subsidy based on a percentage of electricity bills, it is clear that the subsidy is to meet a certain percentage of expenditure on power. The receipt is, therefore, revenue in nature and is covered by the decision of this court in Sahney Steel and Press Works Ltd. v. CIT. The appeal is allowed accordingly. There will, however, be no order as to costs.