1979 (7) TMI 150

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....by this order. 2. The first point is with reference to the disallowance of 1/4th amount paid to the foreign collaborator as contribution towards research and development and the question was whether this could be considered as revenue expenditure or no. The amounts involved were Rs. 86,334 paid to M/s. Wavin B.V. Zwolle for the asst. yr. 1973-74 and Rs. 1,00,984 for the asst. yr. 1974-75. On this....

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....ration Ltd. vs. CIT 1977 CTR (SC) 151 : (1977) 107 ITR 195 (SC) held in favour of the assessee. We agree with the AAC that two units established at Ghaziabad and Nagpur were altogether new units which never existed earlier in those places and merely because it was also to manufacture PVC pipes which were manufactured in Madras it would not militate against the claim of the assessee. So far as the ....