https://www.taxtmi.com/caselaws?id=38216 Compensation for compulsory deprivation of the right to manage a life insurance business was held to be a capital receipt because the management right was an integral incorporeal asset of the assessee's profit-making apparatus. The legislative takeover permanently sterilised that capital asset and altered the trading structure, so the payment was not made for a mere loss of user or ordinary business income. The later insertion of section 28(ii)(d) of the Income-tax Act, 1961 did not apply to the relevant assessment year and could not change the position under the earlier law. The compensation was therefore not taxable as revenue income. en-us Wed, 03 Aug 1977 00:00:00 +0530 Sat, 03 Apr 2010 18:29:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38216 Compensation for compulsory deprivation of the right to manage a life insurance business was held to be a capital receipt because the management right was an integral incorporeal asset of the assessee's profit-making apparatus. The legislative takeover permanently sterilised that capital asset and altered the trading structure, so the payment was not made for a mere loss of user or ordinary business income. The later insertion of section 28(ii)(d) of the Income-tax Act, 1961 did not apply to the relevant assessment year and could not change the position under the earlier law. The compensation was therefore not taxable as revenue income. Case-Laws Income Tax Wed, 03 Aug 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38216