Payment for rights to use know-how and technology without ownership is revenue expenditure

Brief facts of the case- The respondent-assessee Hero Motocorp Limited, earlier known as Hero Honda Motors Limited, was a joint venture between the Hero Group and Honda Motorcycle Company Limited, Japan. for manufacture and sale of motorcycle using technology licenced by Honda. For the above purpose ,they both have entered into a ‘license and technical assistance agreement’ in which Honda will provide know-how to manufacture ,assemble, sell and otherwise deal with two/three wheelers and their parts as a joint venture .Hero Motors Limited have to pay royalty, Model Fees and technical guidan...