Payment for Technical Know-How Use Classified as Revenue Expenditure, Not Capital, Due to Lack of Ownership Rights.

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....Nature of expenditure - amount paid as fee for user of know-how - capital expenditure or revenue expenditure - where an assessee who is engaged in the business of manufacturing and selling certain products had made a payment to a foreign company for merely acquiring a right to use technical know-how, whereas the ownership and intellectual property rights in the said know-how remained with the foreign company, then, the payment in question would be in the nature of a revenue expenditure - AT....