Assistant Commissioner Of Income Tax vs Jasubhai Business Service (P) Ltd. on 29 July, 2005
11. The Authorised Representative also relied upon the decision of Hon'ble Madras High Court in the case of CIT v. Aquapump Industries (1996) 132 CTR (Mad) 506 : (1996) 218 ITR 427 (Mad). In this case, the Court mainly dealt with the transfer of technical know-how for a period of 5 years and payment of royalties consideration thereof and the Court held that the expenditure was revenue in nature. However, in the instant case, there is no such issue of transfer of technical know-how and payment of royalty, hence the ratio of the above-mentioned case has no bearing on the facts of the present case.