COMMISSIONER OF INCOME TAX DEL vs. SRIRAM PISTONS & RINGS LTD.

2003 . Having heard learned counsel for the parties, we are of the view that the order of the Tribunal involves substantial questions of law. Admit. The following questions of law are framed for adjudication : ''1, Whether the ITAT was right in holding that the entire royalty payment of Rs. 102,60,070/- made by the assessee to kilbenschimdt, Germany, Honda Foundry, Japan, Riken Corp. Japan and Fuji Ooxz, Japan is revenue expenditure and no part of it can be re garded as capital expenditure? .

Whether ITAT was right in holding that the entire expenditure of Rs. 18,73,465/- incurred by the assessee on visits of foreign technicians and other related expenditures under collaboration agreements is revenue expenditure and no part of it/25% o f the said expenditure can be regarded as capital expenditure?'' . The appellant shall file within three months ten copies of the cyclostyled paper books, containing all documents on which reliance was placed before the Tribunal, including any order/orders, either in the case of the assessee itself or in case of any oth er assessee, which has been followed by the Tribunal. The appeal be listed for hearing in the regular course. . . D.K. JAIN, J . . MADAN B. LOKUR, J SEPTEMBER 02, 2003 rkr