Goodwill Transfer Treated as Capital Receipt, Not Revenue; Consideration for Assets and Rights, Not Goodwill Itself.

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....Assessee had transferred as per the agreement goodwill to client which AO contested that it cannot be treated as a capital receipt and be treated as a revenue receipt and brought to tax under the head "Profit and Gains of Business' - consideration paid is not for the goodwill but it is for the assets, properties and rights of the transferor hence treated as capital receipt - HC....