No addition u/s. 28(iv) for free of cost assets from sister concern as no benefit derived

ACIT Vs Sony India Software Centre Pvt. Ltd. (ITAT Bangalore) ITAT Bangalore held that addition under section 28(iv) of the Income Tax Act for receiving fixed assets from sister concern on free of cost basis unjustified as no benefit is derived from the same. Accordingly, order of CIT(A) upheld and appeal of revenue dismissed. Facts- The assessee company is engaged in the business of providing software development services. During the course of assessment proceedings, it was found that assessee has received certain assets free of cost from various sister groups located outside India. These AEs...