https://www.taxtmi.com/caselaws?id=37858 Royalty paid under a limited technical collaboration arrangement may be apportioned on a factual basis between revenue and capital components where the agreement does not show an outright acquisition of an enduring capital asset. On the facts noted, 50% of the royalty was treated as revenue expenditure, while the balance capitalised amount was attributable to plant design and know-how and was eligible for depreciation and development rebate. Fencing around refinery processing units was also treated as plant entitled to depreciation and rebate. The Bombay High Court therefore accepted the assessee's tax treatment on all three questions. en-us Wed, 30 Nov 1977 00:00:00 +0530 Thu, 01 Apr 2010 14:15:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37858 Royalty paid under a limited technical collaboration arrangement may be apportioned on a factual basis between revenue and capital components where the agreement does not show an outright acquisition of an enduring capital asset. On the facts noted, 50% of the royalty was treated as revenue expenditure, while the balance capitalised amount was attributable to plant design and know-how and was eligible for depreciation and development rebate. Fencing around refinery processing units was also treated as plant entitled to depreciation and rebate. The Bombay High Court therefore accepted the assessee's tax treatment on all three questions. Case-Laws Income Tax Wed, 30 Nov 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37858