Fee to allow use of technology for 3 yrs without supply of know-how during that period was taxable i

IT/ILT : Where assessee, a subsidiary of US based company, entered into an agreement during relevant year whereby it received certain amount as licence fee for granting right to use technology relating to manufacturing a particular model of tractor for three years, in view of fact that after execution of agreement, no services or know-how was to be supplied during next three years, entire licence fee was to be taxed in assessment year in question even though payment had to be deposited in escrow