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Guide on section 278 of Income Tax Act - Taxability of certain income

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Last Updated: 01-04-2026

278.1 Taxability of certain income

Section 278

Following income shall be chargeable on receipts or certainty basis

 

278.1.1 Interest on compensation is chargeable on receipt basis

Section 278(1)

Any interest received by an assessee on any compensation or on enhanced compensation,

shall be deemed to be the income of the tax year in which it is received,

irrespective of anything to the contrary contained in section 276.

 

278.1.2 Escalation of Price is chargeable when reasonable certainty acjheived

Section 278(2)

Any claim for escalation of price in a contract or export incentives

shall be deemed to be the income of the tax year in which reasonable certainty of its realization is achieved.

 

278.1.3 Subsidy, grant etc from govt is chargeable on receipts basis

Section 278(3)

The income referred to in section 2(49)(w)

shall be treated as the income of the tax year in which it is received, if not charged to income-tax in any earlier tax year.

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Section 2(49)

Income includes

(w) Assistance in the form of a subsidy or grant or cash incentive or duty drawback or waiver or concession or reimbursement (by whatever name called)

by the CG or a SG or any authority or body or agency, in cash or kind, to the assessee

other than

(i) subsidy or grant or reimbursement which is taken into account for determination of the actual cost of the asset as per section 39(1)(d) and (3); or

(ii) subsidy or grant by the CG for the purpose of the corpus of a trust or institution established by the CG or a SG,