hitherto rendered by our collaborator M/s Entek IRD UK due to
cessation of collaboration with them the company needed technical
assistance as the company ... separate agreements, namely
collaboration agreement and sales representative agreement. Through
the collaboration agreement, Entek IRD, U.K. were to extend technical
and financial support
part of the world and to act as consultants, advisors, experts,
technical collaborators, valuers, surveyors, inventory analysts in all matters,
pertaining to setting
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
held that the assessee had entered into foreign technical collaboration with UOP for
getting technology, that it had entered into two agreements on the same ... getting technical
information with regard to BEDS, that both the agreements were part of composite agreement
for getting the technical collaboration, that from the license
holding in order to give its approval for
continuation of a technical collaboration arrangement with its parent company.
In these set of facts
ended 31-3-1980 royalty of Rs. 1,96,53,025 and technical fees from J.K. Synthetics Ltd. of Rs. 36,48,599 amounting ... technical know-how as provided for under Article 3.
(c) 171 (one hundred seventy one) million Italian Lire for the supply of technical collaboration
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
technical arrangement to run profitably, What,
therefore, motivated the businessman in the assessee
was the expediency of ensuring the continuance of the
technical collaboration arrangement ... obtain the approval of the Government
to the continuance of the technical collaboration
arrangement. That being the object and purpose, the said
expenditure was revenue
valid method to benchmark the transactions. The
technical collaboration agreement as referred to by Ld. TPO did not envisage
any such express arrangement/agreement between
price of
products manufactured and sold in India as per the technical
collaboration agreement. This international transaction involving
payment of royalty
