Manisana, J.
1. In this reference under Section 256(1) of the Income-tax Act, 1961, we are to answer the following question :
'Whether, under the facts and in the circumstances of the case, the Tribunal was justified in law in holding that the grant-in-aid received by the assessee-firm from the Government of Assam was a revenue receipt ?'
2. Facts :--The assessee-firm is a producer of Assamese films and had prodxiced a film titled 'Sanatan'. The said film was released in the year 1974. During the assessment year under consideration, a sum of Rs. 37,488 was received by the assessee as grant-in-aid from the Government of Assam. The said grant-in-aid was equivalent to the first 12 months' collection of amusement tax from the date of release of the film. The assessee had claimed that the said grant-in-aid given by the Government is not a revenue receipt for the reason that the financial aid or subsidy was given by the Government with a view to encouraging the Assamese film industry.
3. The question which, therefore, arises for consideration is whether such a grant-in-aid is a revenue receipt.
4. The grant-in-aid in question is a financial aid or subsidy given by the Government of Assam with the view to encouraging the Assamese film industry. In Section 2(24) of the Income-tax Act, it is declared that ' 'income' includes' such and such which are enumerated therein. In Section 2(24), the interpretation clause, such a grant-in-aid has not been included as an income or a revenue receipt. Therefore, considering the use of the word 'include' in Section 2(24), the word 'income' shall be construed as comprehending not only those which Section 2(24) declares that they shall include but also such things as it signifies according to its natural import. Since Section 2(24) has not declared that such a grant-in-aid shall include, the word 'revenue' shall be construed as comprehending what it signifies according to its natural import. In relation to business undertaking, the word 'revenue' connotes incomings of the undertaking which are products of the normal working of the undertaking. The giving of financial aid or subsidy is at the discretion of the Government. The grant-in-aid in question was not a product of the normal business activities. Therefore, such a grant-in-aid is not a revenue receipt so as to form part of the total income. Accordingly, we answer the question in the negative, against the Department and in favour of the assessee-firm. No costs.