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For the reasons stated in the preceding paragraphs, we are of the considered opinion that no benefit of enduring nature had accrued to the assessee under the agreement dt. 30th June, 2012 entered into by the assessee with OLL and OTL and the licence fee paid by the assessee under such an agreement is in the nature of Revenue expenditure, which is allowable

Shanti Prime Publication Pvt. Ltd.

Section 37 of the Income Tax Act, 1961—Business Expenditure—Capital or revenue Expenditure— Payment made by assessee towards license fee was allowable as revenue Expenditure as assessee having acquired only a limited right to use the technical information, regulatory approval and related information to commercialise and market the products in India while the ownership remained with the licensor— Eli Lily & co vs. Deputy Commissioner of income tax [2019] 202 TTJ (Delhi) 206

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