Brand Licensing Expenses allowed As Business / Revenue Expenses

Questions of Law Raised By ITAT:

a) Whether payments made by the assessee to its holding company Nitrex Chemicals India Ltd for the use of its trademark and for the purpose of obtaining expertise in commerce, finance,manufacturing etc. amounted to revenue expenditure instead of capital expenditure?

b) Whether the finding with respect to additions being disallowances of excessive commission on exports in the circumstances of the case is tenable?

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