HC dismissed Revenue's appeal under s.260A, holding that no...

HC dismissed Revenue's appeal under s.260A, holding that no substantial question of law arose from the ITAT order. On taxability of receipts u/s 28(iv) and their inclusion in book profits u/s 115JB, HC held the issues were concluded against Revenue and in favour of assessee by binding SC precedents. On the alternative plea to tax the receipt as "income from other sources" u/s 56 on the footing that a company cannot gift to another company, HC refused to entertain the contention as it did not arise from the ITAT's factual findings. ITAT's relief in favour of assessee stood affirmed.