2014 (8) TMI 1027

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....assed by the CIT (A) on 26.02.2013 in relation to the assessment year 2009-10. 2. The only effective ground is against treating royalty payment of Rs. 8,64,67,558/- as revenue expenditure against the AO's point of view of such amount being capital expenditure. 3. Briefly stated, the facts of the case are that the assessee paid, inter alia, royalty of Rs. 8.6 crore to its Associate enterprise M/s....

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....This Agreement, a copy of which is available on record, makes it clear that its duration is five years subject to further renewal. Clause 5.2 of the Agreement provides that it may be terminated at any time by mutual consent of the parties. Clause 2.1 of the Agreement makes it explicitly clear that it grants the assessee a non-exclusive right to use the trade mark and trade name in the licensed bus....