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NOTE:
Court Rules Royalty Payments as Revenue Expenditure, Not Capital, Due to No Enduring Benefit from Technical Know-How Use.
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Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee is not authorised to transfer, assign or convey the know how/technical information to any third party - payment was for mere use of technical know-how, not resulting in any enduring benefit - revenue exp.