https://www.taxtmi.com/caselaws?id=386632 ITAT RAIPUR - AT held that the assessee did not manage the whole or substantially the whole affairs of the company and the Rs. 1.75 crore received was not shown to relate to relinquishment of managerial rights. Even if it were, following SC precedent (B.C. Srinivasa Setty) the cost of such a managerial right is indeterminate, making capital gains computation unworkable. Consequently the amount was neither taxable as business income under s.28 nor as capital gain under s.45. The Tribunal upheld the CIT(A)'s order and dismissed Revenue's grounds. en-us Mon, 01 Jul 2019 00:00:00 +0530 Thu, 13 Nov 2025 14:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386632 ITAT RAIPUR - AT held that the assessee did not manage the whole or substantially the whole affairs of the company and the Rs. 1.75 crore received was not shown to relate to relinquishment of managerial rights. Even if it were, following SC precedent (B.C. Srinivasa Setty) the cost of such a managerial right is indeterminate, making capital gains computation unworkable. Consequently the amount was neither taxable as business income under s.28 nor as capital gain under s.45. The Tribunal upheld the CIT(A)'s order and dismissed Revenue's grounds. Case-Laws Income Tax Mon, 01 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386632