Mahindra & Mahindra Ltd. v. ACIT (2020) 184 ITD 621 (Mum.)(Trib.)

S. 28(iv) : Business income-Value of any benefit or perquisites-Converted in to money or not-Premature payment of deferred sales tax at Net Present Value of certain amount against total liability-capital receipt-Not assessable as business income.

Tribunal held that payment made premature payment of deferred sales tax at Net Present Value of certain amount against total liability, said amount was a capital receipt and it could not be treated as business income. (AY. 2005-06)