Transfer of 'Essar' Brand to Trust Deemed Non-Taxable Gift, Not Income, u/ss 2(24) and 56(1.

Value of the ‘Essar’ brand, trademarks and copyrights purported to have been settled by EIL to the assessee without any consideration, constituted taxable income as per section 56(1) - the CIT(A) had rightly concluded, that as the contribution of brand “Essar” as a gift by EIL to the corpus of the assessee trust did neither involve any profit element which could be brought within the meaning of “Income” under Sec. 2(24) of the Act, nor partook the nature of income, therefore, it could not be subjected to tax under the residuary head i.e “Other sources” u/s 56(1) of the Act, thus, uphold his view to the said extent. - AT .....

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