https://www.taxtmi.com/caselaws?id=69776 Payments made by a non-owner to foreign collaborators for patent-right use were treated as revenue expenditure where the assessee obtained only limited use of the patents, without acquiring any enduring or capital asset. The amount was characterised as reimbursement of patent-registration-related costs and part of the expense of obtaining technical know-how, not capital outlay. On reassessment, internal revenue audit information on a pure question of law was stated to be insufficient material for reopening under section 147(b), especially where the relevant facts were already on record. The commentary concludes that the expenditure was allowable and that such reopening was invalid. en-us Wed, 30 Jan 1980 00:00:00 +0530 Tue, 12 Apr 2011 10:36:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69776 Payments made by a non-owner to foreign collaborators for patent-right use were treated as revenue expenditure where the assessee obtained only limited use of the patents, without acquiring any enduring or capital asset. The amount was characterised as reimbursement of patent-registration-related costs and part of the expense of obtaining technical know-how, not capital outlay. On reassessment, internal revenue audit information on a pure question of law was stated to be insufficient material for reopening under section 147(b), especially where the relevant facts were already on record. The commentary concludes that the expenditure was allowable and that such reopening was invalid. Case-Laws Income Tax Wed, 30 Jan 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69776