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Supreme Court of India 2020-07-22 allowed

SHIV RAJ GUPTA vs COMMISSIONER OF INCOME-TAX, DELHI-IV

Bench: 3 — R. F. Nariman, Navin Sinha, B.R. Gavai

In Brief

Shiv Raj Gupta, former Chairman of Central Distillery and Breweries Ltd., sold his controlling share to Shaw Wallace group and received Rs. 6.6 crores as a non-competition fee. The Income Tax Department taxed this as compensation for management termination (revenue receipt), but the assessee contended it was a capital receipt from a restrictive covenant. The Supreme Court allowed the appeal on two grounds: (1) the High Court violated Section 260-A by framing a question limited to Section 28(ii)(a) but answering by treating the amount as capital gains without reformulating the question or giving the assessee notice and opportunity; (2) on merits, following established precedent, payments under non-compete covenants are capital receipts, not revenue receipts, and such receipts were not taxable before the 2003 legislative amendment.

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Income Tax Capital Receipts vs Revenue Receipts Non-Compete Clause Restrictive Covenant Appellate Jurisdiction Substantial Question of Law

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