https://www.taxtmi.com/caselaws?id=182966 Lump sums received under successive licensing arrangements for the disclosure and use of technical know-how, drawings and engineering data were treated as trading receipts rather than capital receipts. The House of Lords reasoned that the licensors did not dispose of a fixed capital asset or part with their capital structure; instead, they exploited their existing manufacturing expertise by allowing local manufacture in markets they could not themselves serve. The repeated and deliberate licensing arrangements formed part of a trading policy for deriving profit from know-how, not a once-for-all realisation of capital. The receipts were therefore connected with the business and taxable as trading profits. en-us Wed, 07 Feb 1962 00:00:00 +0530 Wed, 25 May 2016 10:41:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=182966 Lump sums received under successive licensing arrangements for the disclosure and use of technical know-how, drawings and engineering data were treated as trading receipts rather than capital receipts. The House of Lords reasoned that the licensors did not dispose of a fixed capital asset or part with their capital structure; instead, they exploited their existing manufacturing expertise by allowing local manufacture in markets they could not themselves serve. The repeated and deliberate licensing arrangements formed part of a trading policy for deriving profit from know-how, not a once-for-all realisation of capital. The receipts were therefore connected with the business and taxable as trading profits. Case-Laws Income Tax Wed, 07 Feb 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=182966