https://www.taxtmi.com/caselaws?id=256368 Royalty paid under a restricted licence for technical know-how and intellectual property was treated as revenue expenditure because the agreement conferred only limited, non-transferable use rights, while ownership and proprietary control remained with the licensor. The same reasoning applied to the separately payable model fee, as it related to ongoing model development within the existing collaboration and did not transfer any underlying rights. The technical guidance fee was also left undisturbed as deductible revenue expenditure because no agreement or material was produced to show a different character. Where technical know-how is licensed only for limited business use and proprietary rights are retained, the consideration is ordinarily revenue in nature. en-us Tue, 03 Feb 2015 00:00:00 +0530 Mon, 01 Jun 2026 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256368 Royalty paid under a restricted licence for technical know-how and intellectual property was treated as revenue expenditure because the agreement conferred only limited, non-transferable use rights, while ownership and proprietary control remained with the licensor. The same reasoning applied to the separately payable model fee, as it related to ongoing model development within the existing collaboration and did not transfer any underlying rights. The technical guidance fee was also left undisturbed as deductible revenue expenditure because no agreement or material was produced to show a different character. Where technical know-how is licensed only for limited business use and proprietary rights are retained, the consideration is ordinarily revenue in nature. Case-Laws Income Tax Tue, 03 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256368