Principal Commissioner Of Income Tax 5 vs M/S.Redington (India) Limited on 10 December, 2020
and
the decision of the High Court of Judicature at Bombay in Asian Satellite
Broadcast Pvt. Ltd. vs. ITO in W.P.No.2749 of 2019, dated 28.09.2020.
The finding of the Tribunal that the transaction is a gift is a factual finding
and the Revenue cannot challenge the same in the present appeal.