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 & Press Works Ltd. v. CIT (1997) 7 SCC 764. The appeal is allowed accordingly. There will, however, be no order as to costs.