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Non-competition agreement compensation deemed non-taxable capital receipt before April 1, 2003, under Income Tax Act 1961.

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....The Finance Act, 2002 itself indicates that during the relevant assessment year compensation received by the Assessee under non-competition agreement was a capital receipt, not taxable under the 1961 Act. It became taxable only with effect from 1.4.2003. It is well settled that a liability cannot be created retrospectively - HC....