Invocation of powers u/s 263 is legitimate on the ground of lack of compliance with the principle of consistency in allowing certain expenses as revenue expenditure

Advertisement M/s Frick India Ltd Vs DCIT (ITAT Delhi)– There was a composite agreement titled as “intellectual property license and non compete agreement” vide which several valuable rights including the right to use the trademark, technical know-how including right to export to 30 countries have been granted over a long period of ten years to the assessee, which gave rise to a benefit of enduring nature. However, the AO has allowed the same as revenue expenditure without application of mind and without keeping in view the stand taken in earlier years by the AO which was also con...