https://www.taxtmi.com/caselaws?id=13896 The dominant issue was whether consideration paid to a foreign collaborator for technical know-how, discharged by issue of equity shares, constituted revenue expenditure deductible under s.37 of the Income-tax Act or capital expenditure eligible only for depreciation. Relying on SC authority holding that where technical know-how is obtained in exchange for equity shares-particularly by a new company-the outlay is not revenue in character but confers an enduring advantage, the HC held the Tribunal erred in treating it as revenue expenditure. The payment was determined to be capital expenditure, with only depreciation allowable as per law, and the reference was answered in favour of the Revenue. en-us Wed, 21 Mar 2001 00:00:00 +0530 Tue, 06 Jan 2026 00:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13896 The dominant issue was whether consideration paid to a foreign collaborator for technical know-how, discharged by issue of equity shares, constituted revenue expenditure deductible under s.37 of the Income-tax Act or capital expenditure eligible only for depreciation. Relying on SC authority holding that where technical know-how is obtained in exchange for equity shares-particularly by a new company-the outlay is not revenue in character but confers an enduring advantage, the HC held the Tribunal erred in treating it as revenue expenditure. The payment was determined to be capital expenditure, with only depreciation allowable as per law, and the reference was answered in favour of the Revenue. Case-Laws Income Tax Wed, 21 Mar 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13896