Sale of technical concept claimed as capital receipt  as no cost of acquisition was incurred . Dismissing the appeal of the assessee the Tribunal has applied test of human probabilities has to be applied to decide whether what is apparent is real. A technical concept was conceptualized by assessee-employee to safeguard websites from getting infected with malware against consideration and thereafter, an agreement was entered into between assessee, employer-Indusface India, Indusface Canada, and Trend Micro USA, for sale of all rights in concept so developed/against consideration and claim of assessee was that amount received by assessee from Trend Micro was a capital gain in his hands, but as it had no cost of acquisition, this capital gain was not taxable in nature, since a perusal of Asset Purchase Agreement clearly shows that dominant intention of purchaser for making payment to assessee was to prevent him from engaging in any business which could have competed with business purchased by Trend Micro from sellers, amount received by assessee is revenue receipt in his hands and is taxable as business income under section 28(va). Further, in any case, cost of acquisition, in case of non compete rights, under section 55(2)(a) is to be taken as NIL, and, as a corollary thereto, entire receipts is to be taxed in hands of assessee. Tax authorities are not required to put on blinkers while looking at documents. They are entitled to look into the surrounding circumstances to find out the reality.  ( ITA No.: 1954/Ahd/ 2017, dt. 08.02.2019)(AY: 2013-14)