Receipt for Hospital Closure: Goodwill or Capital? Tax Implications u/ss 28(1) & 28(IV) of Income Tax Act.

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....Nature or receipt - goodwill for closing down own hospital - Addition u/s 28(1) or 28(IV) or capital receipt - The reasoning of the ld. CIT(A) that since the name of the new entity is different than the assessee’s clinic called Mother and Child, the agreement is not to be believed. It is noted that it is the doctor and the skill which has got reputation and not the name board of the said clinic. Hence, the ld. CIT(A)’s finding fault in the non-user of assessee’s own clinic name is not sustainable. - AT....