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2010 (3) TMI 689 - HC - Income TaxIncome received from licensing of immovable property - Income from business or as Income from other sources - assessee submitted that income treating the rental/licensing income as assessable under the head of profit and gains of business was accepted by the Revenue - assessment years 1993-94 and 2001-02 the assessments were completed under section 143(3) whereby the Assessing Officer had accepted the submission that the licence fees received by the assessee were business income - Held that: - Matter remanded back to the Tribunal for reconsideration - Expenses incurred by the appellant in relation to training of an employee abroad - According to Tribunal it was not wholly and exclusively for the purpose of the business - Held that: - assessee was not able to substantiate that sending employee for training abroad was for the benefit of the business of the assessee - Counsel appearing on behalf of the assessee fairly placed on record the judgment of the Division Bench in the case of Echjay Forgings Ltd. v. Asst. CIT, where this court affirmed the decision of the Tribunal for similar reasons appeal is disposed of accordingly
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