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    <title>2007 (12) TMI 240 - ITAT DELHI</title>
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    <description>The Tribunal held that the non-compete fee received by the assessee was a capital receipt, not subject to tax under any income head specified in section 14 of the Income-tax Act. It determined that the fee did not arise from an employer-employee relationship and was not taxable under sections 28(ii), 28(iv), or as capital gains or income from other sources. The Tribunal dismissed the grounds challenging the reopening of the assessment under section 147, as these were not pressed by the assessee&#039;s counsel. The appeal was allowed in favor of the assessee.</description>
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    <pubDate>Fri, 07 Dec 2007 00:00:00 +0530</pubDate>
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      <title>2007 (12) TMI 240 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=62741</link>
      <description>The Tribunal held that the non-compete fee received by the assessee was a capital receipt, not subject to tax under any income head specified in section 14 of the Income-tax Act. It determined that the fee did not arise from an employer-employee relationship and was not taxable under sections 28(ii), 28(iv), or as capital gains or income from other sources. The Tribunal dismissed the grounds challenging the reopening of the assessment under section 147, as these were not pressed by the assessee&#039;s counsel. The appeal was allowed in favor of the assessee.</description>
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      <pubDate>Fri, 07 Dec 2007 00:00:00 +0530</pubDate>
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