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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.
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.
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