Loan ‘waiver’ does not fall into either of three terms subsidy / grant and reimbursement

RELEVANT PARAGRAPH 7. We have considered the rival submissions of the parties and perused the materials on record. The undisputed facts are that the assessee had plant and machinery already existing prior to the receipt of finance from Wipro Finance Ltd. It is apparent from the chart of payment referred to by the learned AR of the assessee. This clearly indicates that the loan was not given directly or indirectly for the purpose of purchasing plant and machinery. The argument of the Assessing Officer, CIT(A) and the learned DR that the loan from Wipro Finance Ltd., was used to repay the suppli...