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Showing contexts for: currency defined in Cit vs Eicher Motors Ltd. on 18 October, 2006Matching Fragments
4. Necessary facts are undisputed. The assessee, a public limited company, is an automobile manufacturer. It entered into a technical assistance agreement with Mitsubishi Motors Corporation (MMC) Japan, for a licence to use and utilize technical know-how and drawings, designs etc. to manufacture the light commercial vehicles (LCVs) and sale thereof under the brand name of MMC in the defined territory during the currency of the licence agreement. It was agreed between the parties that the assessee would pay royalty in periodic instalments at 3 per cent, of MMC FOB Japanese port price, for the use of technical know-how and assistance and information and services provided for manufacture/assembly of licenced products. The assessee, as a licensee, paid royalty under the agreement to MMC in different assessment years as under: