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    <title>2026 (6) TMI 131 - ITAT AHMEDABAD</title>
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    <description>A whistleblower reward received from the US Securities and Exchange Commission was treated as taxable income under the inclusive definition in section 2(24) of the Income-tax Act, 1961. The receipt was not regarded as a gratuitous windfall or capital receipt because the claimant knowingly pursued the complaint, gathered evidence, engaged counsel on a success-fee basis, filed a reward claim, and actively assisted the enforcement process. That conduct established quid pro quo, so the payment arose from a conscious anticipated course of action rather than an unforeseen bounty. The reward was also held outside the exemption in section 10(17A) and taxable under the head income from other sources.</description>
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