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    <description>Payments under a technical collaboration agreement for use of confidential know-how and related assistance were treated as revenue expenditure because the assessee acquired no capital asset or enduring advantage, and the expenditure was directed to efficient conduct of the existing manufacturing business. Where remittance to a non-resident was legally restricted until Reserve Bank of India approval, the liability did not accrue before such approval; once approval and remittance occurred in the relevant previous years, the amounts became deductible in those years. The ratio is that use of technical know-how in the profit-making process is revenue in nature, while statutory approval can determine the timing of accrual for deduction.</description>
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