assessee,on royalty remitted to Unilever Plc.-under the Technical
Collaboration Agreement,between the assessee and the AE-was excessive.It alternatively
held that
personal care and
hygiene related products. It has entered into technical collaboration and
trademark licence agreement with two Indian concerns, namely, M/s.
Procter
price of products manufactured and sold in India as
per the technical collaboration agreement. This internatio-
nal transaction involving payment of royalty
Trib.) 0632 ITAT Delhi Bench have held that agreement for technical
collaboration royalty payments towards right to use technical know-how and patents
with
company is engaged in the manufacture of portable
generator sets in technical collaboration with Honda Motor
Company, Japan. In this civil appeal, we are concerned
Commissioner of Income Tax (Appeals) erred in
holding that the technical collaboration fees instalment
paid of Rs.28,70,000/- was claimed as revenue expenditure ... collaborator M/s. Exedy Corp. Japan. While remitting the
said technical know-how, the company deducted the tax which was
deposited in view
terms of building
up of a technology base through relevant stakeholders and
collaborators, lurther supported by market analysis and import- export
imperatives.
The focus ... committed management team
° Experienced scientists and technical team
° Innovation
° Tremendous opportunity in Bio-Services and product
° Technological collaboration with leading research institutions
that the assessee
has paid donation to set up a technical training institute in collaboration
with NTTF, a renowned skill development institute which involved
sales towards
technical knowhow. However, as per the subsequent agreement
though the rate of royalty for technical knowhow was reduced to
1.25% of the sales ... royalty for technical knowhow subsumes the
payment of royalty for the use of trademark and brand name of
foreign collaborator. He observed, the assessee
National Institute Of Bank Management, ... vs Acit (Exemption) - 2(1), Mumbai on 25 January, 2018