It appears that the appellant has acquired sublicense for using Monsanto technology and such sublicense is non transferable. Such license is provided to the assessee to test produce and sell genetically modified hybrid cotton plant seeds in the territory of the appellant for effectively increasing its business; no asset, however, is created. While holding such expenses as revenue expenditure the Ld. CIT(A) relied upon the judgment passed by the Hon'ble Delhi High Court in the matter of CIT vs. J K Synthetic Ltd. reported at309 ITR 371wherein it was held that since under the agreement the assessee has obtained a technical assistance and acquired some technical information which was a knowhow related to process of manufacture, then it is not a transfer of the ownership of the knowhow and to be treated as revenue expenditure.