Suzuki India agreed to pay a sum of Rs. 1,32,00,000 to the appellant, in consideration of the appellant , who was managing director of joint venture company of Suzuki India for not providing "the benefit of his knowledge of regulatory matters, negotiating skills and strategic planning expertise to any other person in India in the two wheeler segment for a period of two years from the date of the Agreement". Held by ITAT Delhi in Satya Sheel Khosla NOVEMBER 10, 2015 [2015] 63 taxmann.com 293 (Delhi - Trib.) 1. Clause (va) of section 28 of the Act taxes a sum received for a restrictive covenant in relation to a business, but not a profession. Book of Kanga and Palkhivala relied upon. 2. Further Amount received by managing director of the company for managing all affairs of the company; evolving business strategies; and advising the company is not profit in lieu of salary because managing director is not employee as per purview of his duties. Supreme Court in Ram Prashad [1972] 86 ITR 122 relied upon.