Tribunal held that the payment of user licence fees based on turnover was deductible as revenue expenditure. The assessee had been merely granted a licence to use the trade mark on payment of licence fee determined on the basis of a formula laid down in the agreement. The right to use could neither be assigned at the wishes of the licensee nor was the licensor prohibited to terminate the user licence agreement executed with the licensee. Thus, the licensor retained the inherent control over the manner of use of trade mark. Thus the licence fee paid for mere use of the capital asset which continued to belong to someone else thus could not be regarded to be in the capital field in the hands of licensee. (AY.2012-13 to 2014-15)