https://www.taxtmi.com/caselaws?id=62887 ITAT held that payments made by the assessee for obtaining rights to reproduce sound recordings from master plates constitute revenue expenditure, not capital. The master plates were treated as raw material, formula or design, used solely for making identical copies, with the assessee functioning as a job-worker. Both the lump-sum and recurring royalty payments, being linked to sales and contingent on commercial exploitation, were held to be deductible in computing business income. On jurisdiction, ITAT ruled that the CIT had improperly invoked s.263 merely to substitute his opinion for that of the AO, without demonstrating any error causing prejudice to the Revenue. The s.263 order was quashed and the assessee's appeal allowed. en-us Mon, 30 Mar 1992 00:00:00 +0530 Wed, 10 Dec 2025 19:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62887 ITAT held that payments made by the assessee for obtaining rights to reproduce sound recordings from master plates constitute revenue expenditure, not capital. The master plates were treated as raw material, formula or design, used solely for making identical copies, with the assessee functioning as a job-worker. Both the lump-sum and recurring royalty payments, being linked to sales and contingent on commercial exploitation, were held to be deductible in computing business income. On jurisdiction, ITAT ruled that the CIT had improperly invoked s.263 merely to substitute his opinion for that of the AO, without demonstrating any error causing prejudice to the Revenue. The s.263 order was quashed and the assessee's appeal allowed. Case-Laws Income Tax Mon, 30 Mar 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62887