Patent licence valuation: competing expert reports led to a non-precedential lump-sum valuation and consequential tax computation.

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....Valuation of consideration for a limited patent-use licence turned on materially divergent expert reports applying an internationally accepted cost approach and a substantially higher departmental valuation. Neither valuation position was accepted in full. A lump-sum estimate was adopted in the interest of justice, expressly without precedential effect, fixing the amount attributable to the limited patent-use right at USD 900,000. Consequential computation was directed in accordance with law, and the appeal was partly allowed to that extent.....