2020 (1) TMI 926

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....LLANT ORDER (PER : HONOURABLE MR.JUSTICE J.B.PARDIWALA) 1 This Tax Appeal under Section 260A of the Income Tax Act, 1961 (for short, 'the Act, 1961') is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad 'B' Bench, dated 27th March 2019 in the ITA No.2796/Ahd/2014 for A.Y. 201112. 2 The Revenue has pro....

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....ons recorded by us today, while dismissing the Tax No.834 of 2019, this Tax Appeal stands dismissed so far as the questions Nos.2[A] and 2[B] respectively, as proposed by the Revenue, is concerned. The question No.2[C], as proposed, is one relating to deletion of addition of Sub License Fee Expenses to the tune of Rs. 27,57,500/. In this regard, the Tribunal, while concurring with the finding reco....

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....nical information which was a knowhow related to process of manufacture, then it is not a transfer of the ownership of the knowhow and to be treated as revenue expenditure. The judgment passed by the Coordinate Bench, in the case of Urja Products Ltd. was also mentioned in the order passed by the Ld. CIT(A) wherein similar issue has been decided in favour of the appellant. The nonrefundable upfron....