1980 (3) TMI 16

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....referred the following question for the opinion of this court: " Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the sum of Rs. 50,652 is allowable as a revenue expenditure ? " The assessee had entered into collaboration agreements with two Japanese companies. The business of the assessee consisted in the manufacture of electric compon....

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....ore the Tribunal, on the ruling of this court in the case of Mysore Kirloskar Ltd. v. CIT [1968] 67 ITR 23. The Tribunal hold that the facts in the instant case were distinguishable and it observed as follows: " The real point for consideration is whether the payment of royalty to the two Japanese companies was for the right to manufacture the licensed articles or for the actual user of the techn....