Payment made for supply of technical know-how services for setting up cellular telecom services is capital expenditure

RELEVANT PARAGRAPH 35. In the case before us, the Agreement between the assessee and DCIL/Distacorn and Modicorp is to assist the assessee by providing services in the manner set out in Schedule – 1 to the Agreement, [n the Agreement, it has been clearly provided that DCIL and Distacom have technical and operational know-how and capability which are necessary to the success of assessee’s business in providing cellular communications services in the states of Karnataka & Punjab (India) and the fulfillment of its obligations under the Agreement between assessee and the Department...