Technical fee for setting up of new plant for first time to manufacture cars is revenue expenditure

Assessee in all these appeals is Honda SIEL Cars Ltd. (hereinafter referred to as the “Assessee”). Question of law that is raised is also identical. Five appeals are filed only because of the reason that same issue has occurred in different Assessment Years, i.e., for the years 1999-2000, 2001-2002, 2002-2003, 2003-2004 and 2005-2006. 2) M/s. Honda Motors Company Limited, Japan (hereinafter referred to as “HMCL, Japan”) had entered into a joint venture dated September 12, 1995 with M/s. SEIL Ltd., a company incorporated under the Indian Companies Act. After getting necessary approval f...