https://www.taxtmi.com/caselaws?id=211754 The Tribunal allowed the license and technology fees as revenue expenditure, overruling the capital expenditure treatment by the AO and CIT(A). The deduction under Section 80HHC was disallowed while computing book profit under Section 115JB, following the Supreme Court's judgment. Reopening of assessment under Section 147 and the notice under Section 143(2) were deemed unnecessary due to the allowance of the assessee's claims. The claim for depreciation if royalty payment was disallowed became irrelevant as the Tribunal considered the payment as revenue expenditure. en-us Wed, 21 Dec 2011 00:00:00 +0530 Tue, 03 Apr 2012 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211754 The Tribunal allowed the license and technology fees as revenue expenditure, overruling the capital expenditure treatment by the AO and CIT(A). The deduction under Section 80HHC was disallowed while computing book profit under Section 115JB, following the Supreme Court's judgment. Reopening of assessment under Section 147 and the notice under Section 143(2) were deemed unnecessary due to the allowance of the assessee's claims. The claim for depreciation if royalty payment was disallowed became irrelevant as the Tribunal considered the payment as revenue expenditure. Case-Laws Income Tax Wed, 21 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211754