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8. Before the Ld. CIT (A), the assessee submitted that 'royalty agreement' entered with JM UK was duly approved by RBI and Foreign Investment Promotion Board (FIPB) and as per the terms of the agreement, royalty was required to be paid for the period of 10 years from the date of commencement of the commercial production or for a period of 13 years from the date of grant of approval from the RBI. Accordingly, the royalty was payable for the period between financial year 1999-2000 to financial year 2008-09. So far as the benefit derived to the assessee under the royalty agreement following facts was stated:-