ITAT apportions exp. on living Germplasm and technical know-how between capital and revenue exp.

IT : Where under a long term licensing agreement, assessee acquired genetic material for cereals, seeds, etc. i.e., organic Germplasm as also technical know-how in bio-technology field along with right to future development and improvement and such technology would benefit assessee even after expiry of agreement period and even assessee could sell germplasm, a part of expenditure paid by assessee would be apportioned as capital expenditure