https://www.taxtmi.com/caselaws?id=5672 A payment made to a foreign collaborator for technical know-how was treated as revenue expenditure because the agreement conferred only a limited licence to use patents and designs in India for a fixed term, subject to renewal approval. The arrangement did not transfer ownership of any capital asset; it gave the assessee a restricted right to use the collaborator's technical knowledge and related facilities. Applying the enduring benefit test, the Court found that the payment was referable to use of the licence rather than acquisition of an enduring asset. The expenditure was therefore revenue in nature and not capital expenditure. en-us Thu, 03 Apr 1997 00:00:00 +0530 Mon, 13 Oct 2025 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5672 A payment made to a foreign collaborator for technical know-how was treated as revenue expenditure because the agreement conferred only a limited licence to use patents and designs in India for a fixed term, subject to renewal approval. The arrangement did not transfer ownership of any capital asset; it gave the assessee a restricted right to use the collaborator's technical knowledge and related facilities. Applying the enduring benefit test, the Court found that the payment was referable to use of the licence rather than acquisition of an enduring asset. The expenditure was therefore revenue in nature and not capital expenditure. Case-Laws Income Tax Thu, 03 Apr 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5672