1984 (2) TMI 66

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..... manufacturer of furnaces, factory ovens, etc. The assessment years under consideration are 1966-67 to 1969-70. On March 1, 1965 the assessee entered into a licensing and technical assistance agreement with M/s. Westinghouse Electric International Co. of U.S.A. for the manufacture of special types of heavy duty industrial fans for a period of ten years. The licensees were granted an exclusive li .....

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..... nical assistance and licence to manufacture. Under the agreement, the assessees were furnished with drawings, specifications, etc., required for the manufacture of the said items and these drawings were to be returned at the termination of the agreement. In this agreement as well as in the previous agreement, there was a provision for training of the assessee's engineers. In respect of the payme .....

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..... years was expenditure of a revenue nature and allowable as such ? 2. Whether, on the facts and in the circumstances of the case, the sum paid to Superior Combustion Industries of New York and written off in each of these years to the extent of 1/5th is revenue expenditure and allowable as such?" The answer to these questions is covered by the ratio laid down in the decision of a Division Benc .....

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