Assignment of user rights in intangible assets, without a...

Assignment of user rights in intangible assets, without a lump-sum price, fixed term, fixed periodic payment, or reversion provision, was characterised as a licence rather than an ownership transfer; variable profit-linked payments were licence fees, and later consideration was capital sale proceeds. Sale proceeds of self-generated trade marks and brands were not taxable as long-term capital gains where the acquisition cost was unascertainable and no retrospective nil-cost deeming rule applied. An arbitral award remained binding between its parties absent an evidential basis to impugn it. Deletion of the underlying addition eliminated the basis for concealment penalty.