Intellectual Property Rights Assignment Deemed Taxable; Assessee's Claim of Capital Receipt Dismissed by Court.

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....Revenue Recognition - gain on sale / Assignment of Intellectual Property Rights (IPR) - The assessee did not receive the sum in question for giving up any source of income as the assessee was free to exploit independently owned IPR as well as Foreground information and therefore the argument that the sum received is capial receipt for losing a source of income and therefore not chargeable to tax, is devoid of any merits. - AT....