- (1.) Leave granted.
(2.) This civil appeal is filed by the revenue against the order passed by the Punjab & Haryana High Court in IT Appeal No. 131 of 2004. The impugned decision is dated 18-5-2006.
(3.) M/s Swaraj Engines Ltd. (respondent herein) entered into an agreement of transfer of technology know-how and trade mark with Kirloskar Oil Engines Ltd. under which royalty was payable (by) it. The claim for deduction in respect of the said payment was made by the respondent. It is important to note that during the relevant assessment year 1995-96, royalty was paid by the assessee as a percentage of net selling price of the licensed goods products.;