R&D Units Purchase Under Technical License Agreement Not Considered Royalty; No Disallowance Warranted for Equipment Acquisition. &D.

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....Disallowance of R & D units purchased as per Technical License Agreement - when the assessee has purchased a product in order to carry out improvements in its technology for future development and its sales thereafter, then such purchases cannot be said to be payment of royalty - the payment was not for use or use of any technology but for purchase of equipment for R&D purpose - no disallowance....