COMMISSIONER OF INCOME TAX Vs. HINDUSTAN MOTORS LTD

JUDGEMENT

(1.) THE following questions of law have been referred to this Court by the Tribunal under s. 256(1) of the IT Act, 1961 : R. A. No. 683 (Cal) of 1984

(2.) THE assessment years involved are the asst. yrs. 1976-77 to 1979-80 for which the relevant accounting periods are the financial years 1975-76, 1976-77, 1977-78 and 1978-79, respectively.

(3.) THE ITO pointed out that the agreement covered a fairly long period of 12 years, after which the assessee would have the property in the information, specification and technique provided by the foreign company and it can exploit the same indefinitely without payment of further consideration.