https://www.taxtmi.com/caselaws?id=797779 Cash exclusivity compensation received when negotiations to transfer subsidiary shares fail is capital in character where exclusivity prevents dealings with other buyers but does not restrict business activity. It is therefore outside business-income taxation under Sections 28(iv) and 28(va) and excluded from book-profit computation under Section 115JB. Section 14A disallowance does not arise for a year with no exempt income; the Finance Act 2022 Explanation applies from assessment year 2022-23 and does not govern an earlier year. en-us Fri, 21 Aug 2026 00:00:00 +0530 Thu, 27 Aug 2026 08:28:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797779 Cash exclusivity compensation received when negotiations to transfer subsidiary shares fail is capital in character where exclusivity prevents dealings with other buyers but does not restrict business activity. It is therefore outside business-income taxation under Sections 28(iv) and 28(va) and excluded from book-profit computation under Section 115JB. Section 14A disallowance does not arise for a year with no exempt income; the Finance Act 2022 Explanation applies from assessment year 2022-23 and does not govern an earlier year. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797779