Mindteck India Ltd. v.Dy CIT (2023)108 ITR 199 (Bang) (Trib)

S. 28(iv) : Business income-Value of any benefit or perquisites-Converted in to money or not-Receipt of equipment from client for testing purpose —Assessee cannot prove negative fact-Addition is not sustainable.

Held that it was clear that the import of the equipment in question from the suppliers was for testing and functionality with respect to the information technology services provided to them by the assessee. The additions made could not be sustained. (AY.2016-17)