Expenditure on R&D for manufacture of aircrafts to be sold allowable U/s. 37

Hindustan Aeronautics Limited Vs ACIT (Karnataka High Court)

The fact that a certain payment constitutes income or capital receipt in the hands of the recipient is not material in determining whether the payment is revenue or capital disbursement qua the payer. It has further been held that whether a transaction is capital expenditure would have to be determined having regard to the nature of the transaction and other relevant factors. In the instant case, the total research and development expenses incurred by the assessee

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