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2021 (3) TMI 54 - AT - Income TaxNature of expenditure - expenses of Technical Know How Fees paid to its parent company - capital or revenue expediture - HELD THAT:- As decided in asseessee' own case [2018 (6) TMI 399 - ITAT DELHI] assessee is already engaged in the business of manufacturing paper machine fabrics and other industrial fabrics and related products. The assessee -obtained a technical know-how in respect of manufacturing of paper maker felts and other industrial fabrics. According to the agreement entered into by the assessee the remuneration was paid for at the rate of 5% on the sale price of the product The Ld. CIT(A) has considered the various clauses of the agreement and held that the know-how was to remain the sole and exclusive property of the provider and the appellant company is required to fully exploit the same. Technical know-how was also in relation to the sales affected by the assessee company, it Is also required to be noted that assessee is engaged in the same business for which technical know-how is by the assessee and it is not at its an altogether a new line of business which is developed. DR could not point out any infirmity in the order of the Ld. CIT(A). In view of above facts we do not find any reason to disturb the finding of the Ld. CIT(A) in allowing the claim of the assessee of technical know-how fees paid to its parent company as revenue in nature - Decided in favour of assessee.
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