“Section 2(24)(vii)”
The decision most relied on for Section 2(24)(vii) is CIT v. Yokogawa India Ltd. (341 ITR 385), cited in 270 judgments on BharatTax.
Leading authorities on Section 2(24)(vii)
A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.
Fees for computer software and technical services are taxable as fees for technical services under the Income Tax Act and are not royalties, unless the software is embedded with an enduring benefit and is integral to the business.
A family arrangement or settlement does not give rise to any income. This is because it represents the working out of existing rights among family members rather than a transfer of property.
The nature of a receipt as capital or revenue is determined by its character in the hands of the recipient, not the payer.