Expenditure having direct nexus with income generating apparatus allowable

The assessee was already into the business of manufacture and supply of manufacture in U.S. Market. The entry into the supply of U.K. market necessitated the designs which are popular in European market. The design charges paid by the assessee to make its product better useful and attractive in European market constitute revenue nature. The reliance placed on Hon’ble Supreme Court judgment in the case of Empire Jute Co. Ltd. (supra) is well placed as the expenditure incurred by the assessee has direct nexus with its income generating apparatus.

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