https://www.taxtmi.com/caselaws?id=63335 The Tribunal classified the royalty payment as revenue expenditure, rejecting the AO's classification as capital expenditure. It emphasized the practical business perspective over strict legal classification, citing relevant case law. The Tribunal allowed the appeal, noting the royalty payment was integral to the profit-making process and not for acquiring a permanent asset. The validity of the contract with HCL, Japan was upheld, and the royalty payment was deemed allowable as business expenditure, following precedents where payments for technical know-how were treated as revenue expenditure. en-us Fri, 04 Jul 2008 00:00:00 +0530 Fri, 20 Jul 2012 12:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63335 The Tribunal classified the royalty payment as revenue expenditure, rejecting the AO's classification as capital expenditure. It emphasized the practical business perspective over strict legal classification, citing relevant case law. The Tribunal allowed the appeal, noting the royalty payment was integral to the profit-making process and not for acquiring a permanent asset. The validity of the contract with HCL, Japan was upheld, and the royalty payment was deemed allowable as business expenditure, following precedents where payments for technical know-how were treated as revenue expenditure. Case-Laws Income Tax Fri, 04 Jul 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63335