2010 (12) TMI 107

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..... MEET KAUR, JJ JUDGMENT 1. The respondent-assessee had claimed certain expenditure allowable as revenue expenditure. This claim of the assessee was disallowed in the assessment proceedings by the Tribunal holding the expenditure to be of capital in nature. On this basis penalty proceedings were also initiated by the Assessing Officer under section 271(1)(c) of the Income-tax Act, 1961. .....

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..... explicit or implied ; whether the assessee derives any other right so as to indicate ownership ; whether the technical know-how always remained the property of SNIC, whether the expenditure incurred was related to the carrying on of the business of the assessee ; whether the assessee had any right to retain, the technical know-how after the termination of the agreement ; as to what was the object .....

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