THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs PVR LTD

$~94-97 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision : 29.04.2025 ITA 113/2025 ITA 115/2025 ITA 116/2025 ITA 117/2025 THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 .....Appellant Through: Mr Ruchir Bhatia, SSC, Mr Anant Mann, JSC Ms Aditi Sabharwal and Mr Abhishek Anand, Advocates. versus PVR LTD .....Respondent Through: Mr Salil Kapoor, Mr Sumit Lalchandani and Ms Ananya Kapoor, Advocates. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (ORAL) 1. The Revenue has filed the present batch of four appeals under Section 260A of the Income Tax Act, 1961 [the Act] assailing a common order dated 23.10.2024 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] dismissing the respective appeals preferred by the Revenue and allowing the cross objections filed by the respondent [Assessee] in the said appeals. 2. The details of the appeals filed by the Revenue and cross objections in 3. The principal question considered by the learned ITAT was whether the subsidies received by the Assessee from the State governments were in the nature of capital receipts? 4. The Assessee had received the Entertainment Tax Subsidy [ET