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Income Tax - Highlights / Catch Notes

Home Highlights July 2014 Year 2014 This

Nature of expenses on Technical know-how fee - such technical ...


High Court Rules Technical Know-How Fee for Manufacturing Existing Items as Deductible Revenue Expenditure, Not Capital Expenditure.

July 3, 2014

Case Laws     Income Tax     HC

Nature of expenses on Technical know-how fee - such technical know-how was used for the purpose of manufacturing the existing items - held as revenue expenditure - HC

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  2. Royalty & lump sum fee – The payment of lump sum fees for the technical know-how and the royalty is allowable as revenue expenditure - AT

  3. Valuation of imported goods - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of...

  4. Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee...

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  6. TDS u/s 195 - the Singapore company as a Consultant has made available to the assessee company technical knowledge in the form of expertise in the operation of its...

  7. Payment to overseas institution as fees for awarding the degrees, supplying books and course material – There is no transfer of any technical know-how or technical...

  8. Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...

  9. TDS u/s 194J - payment to distributors on revenue sharing basis - neither fee for professional or technical services nor royalty - TDS not deductible - no disallowance...

  10. Demand - supply of technical know-how cannot be taxed under "Consulting Engineering Service" - AT

  11. Royalty payment - revenue expenditure or capital expenditure - payment is purely revenue in nature, as they provide for payment of license fee for manufacture and sale...

  12. Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of...

  13. Taxability of amount received on transfer of technical know-how and marketing know-how – there was no cessation of source of income - taxable as revenue receipt - AT

  14. Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

  15. Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

 

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