1983 (6) TMI 4

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.... have been referred to this court for its opinion under s. 256(1) of the I.T. Act, 1961 : " 1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the entire technical aid fees paid by the assessee to M/s. Clayton Dewandre Company Ltd., U.K., and the royalty paid to M/s. Bendix Westinghouse Automotive Air Brake Company, U.S.A., under the ....

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....anufactured, that it was for the purpose of running the business, that merely because the agreement had been entered into soon after the formation of the company, it cannot be stated that the payments under the agreement were liable to be treated as capital expenditure, that the nature of the expenditure is not dependent upon the time at which the relevant agreement came into existence and that th....