ACIT Vs Modi Revlon Pvt Ltd (ITAT Delhi)

ACIT Vs Modi Revlon Pvt Ltd (ITAT Delhi)- The original know-how license agreement was entered into on 14.1.1994 at the time of inception of business of the company and the payments of royalty under that agreement were made till August 2002 i.e. for a period of 7 years from the commencement of agreement as per the approval of the GOI. The payment of royalty in the year under assessment was made in terms of supplement agreement dated 16.9.2003. Hence, there is no question of any fresh input of know ­how/ technology and the payments are only in respect of continued use of brand name and patents ...