https://www.taxtmi.com/caselaws?id=57926 The Tribunal upheld the initiation of proceedings under section 147(a) against a non-resident company for the assessment year 1967-68, determining the taxability of shares received for technical know-how transfer as capital gains. The Tribunal affirmed that once material justifies income escaping assessment, its sufficiency is not justifiable. It held that patents were liable to capital gains as registered capital assets, rejecting the argument to treat the sale of know-how and patents differently. The Tribunal accepted the estimated cost of patents at Rs. 21,000 due to the complexity of determining the exact cost, dismissing both the assessee's and departmental appeals. en-us Thu, 27 May 1982 00:00:00 +0530 Wed, 15 Dec 2010 14:06:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57926 The Tribunal upheld the initiation of proceedings under section 147(a) against a non-resident company for the assessment year 1967-68, determining the taxability of shares received for technical know-how transfer as capital gains. The Tribunal affirmed that once material justifies income escaping assessment, its sufficiency is not justifiable. It held that patents were liable to capital gains as registered capital assets, rejecting the argument to treat the sale of know-how and patents differently. The Tribunal accepted the estimated cost of patents at Rs. 21,000 due to the complexity of determining the exact cost, dismissing both the assessee's and departmental appeals. Case-Laws Income Tax Thu, 27 May 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57926