Sum received on transfer of right to use technical know-how of drug was business receipts and not ca

IT/ILT : Where assessee, engaged in business of manufacture of Active Pharmaceutical Ingredients (API), formed a joint venture company with a South African company, in terms of which assessee sold its technical know how relating to four Anti Petro Viral (ARV) products to joint venture company, in view of fact that assessee merely imparted its special knowledge and experience in field of manufacturing, marketing, selling and distribution of ARVs whereas property in knowhow remained with assessee