TMI Blog2020 (1) TMI 926X X X X Extracts X X X X X X X X Extracts X X X X ..... 008 (12) TMI 21 - DELHI HIGH COURT] wherein the Delhi High Court has taken the view that no under the agreement the assessee has obtained a technical assistance and acquired some technical information which was a knowhow related to process of manufacture, then it is not a transfer of the ownership of the knowhow and to be treated as revenue expenditure. We are in complete agreement with the fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [A] Whether the Appellate Tribunal has erred considering the facts and circumstances of the case and in law, in upholding the order of the CIT(A) for deleting disallowance on account of discount and rate difference to ₹ 2,31,95,051/? [B] Whether the Appellate Tribunal has erred considering the facts and circumstances of the case and in law, in upholding the order of the CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ctive parties, perused the relevant materials available on record. It appears that the appellant has acquired sublicense for using Monsanto technology and such sublicense is non transferable. Such license is provided to the assessee to test produce and sell genetically modified hybrid cotton plant seeds in the territory of the appellant for effectively increasing its business; no asset, however, i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... required to be paid for acquiring license from the main company which is used for the purposes of business and hence the entire expenditure incurred by the appellant is treated as revenue expenditure. We, therefore, find no infirmity in the order passed by the Ld. CIT(A) in deleting such addition of ₹ 27,57,500/as made by the Ld. AO. We, therefore, do not hesitate to confirm the same. So, as ..... X X X X Extracts X X X X X X X X Extracts X X X X
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