https://www.taxtmi.com/caselaws?id=175030 The Tribunal treated the licence-fee disallowance as covered by earlier decisions in the assessee's own case and held that the assessee had discharged the initial burden under section 37(1) by producing material showing technical assistance and business utility. It found no concrete evidence that the payment was a colourable device for profit diversion, and no workable basis had been established to test ordinary profit or excessive remuneration. Later authorities cited by the revenue did not override the binding effect of the prior rulings, so the addition was deleted. en-us Fri, 18 Nov 2011 00:00:00 +0530 Thu, 28 Apr 2016 12:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175030 The Tribunal treated the licence-fee disallowance as covered by earlier decisions in the assessee's own case and held that the assessee had discharged the initial burden under section 37(1) by producing material showing technical assistance and business utility. It found no concrete evidence that the payment was a colourable device for profit diversion, and no workable basis had been established to test ordinary profit or excessive remuneration. Later authorities cited by the revenue did not override the binding effect of the prior rulings, so the addition was deleted. Case-Laws Income Tax Fri, 18 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175030