No addition on account of capitalization of royalty expenses as same is revenue in nature

Honda Motorcycle and Scooter India Pvt. Ltd. Vs ACIT (ITAT Delhi) Conclusion: Payment of royalty by assessee in lieu of granting license under the royalty and technical knowhow agreement was to be treated as revenue in nature as assessee was already engaged in the manufacturing of motorcycle and Scooter and payment of royalty expenses was not with respect to setting up of manufacturing facility. Held: Assessee had entered into certain international transactions with its associated enterprise and therefore reference was made to TPO to determine the arm’s-length price in respect of internation...