Section 4 of the Income-tax Act, 1961 – Income – Chargeable as (Subsidy) – Assessee-company received subsidy from Central Government for technology upgradation of existing units as well as to set up new units with latest technology to enhance their viability and competitiveness in domestic and international markets – In course of assessment, Assessing Officer opined that amount of subsidy received by assessee was taxable as revenue receipt – Tribunal finding that subsidy was clearly for purpose of upgrading machinery and plant and for acquiring capital assets and not for purpose of day-to-day business operations of assessee, held that quantum of subsidy received by assessee was a capital receipt – Whether, on facts, no substantial question of law arose from Tribunal’s order – Held, yes [In favour of assessee]