know-how fee related to grant of technical assistance and continuous know-how, including training of personnel,is revenue in nature

The third installment of know-how fee which related to grant of technical assistance and continuous know-how, in Italy, including training of personnel, in Italy is revenue in nature, any interest paid in relation to delayed payments will also, have to be treated, as one, which is, on revenue account.

 IN THE HIGH COURT OF DELHI AT NEW DELHI

ITR 139/1988 AND ITR NO. 202/1989

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