Tribunal held, that the additional grounds taken by the assessee were identical to those taken for the assessment year 2005-06 wherein the Tribunal had admitted the ground and observed that the proposition of the assessee that the sub-licensing fee, if any, ought to have been excluded on net basis after adjusting the royalty paid against income from sub-licensing because the sub-licensing income and royalty payment had a direct nexus with the know-how agreement but excluding the direct nexus of sub-licensing to the manufacturing activity of the assessee. For the assessment year 2007-08 the facts remained the same. Thus, the Assessing Officer was to compute the sub-licensing fee on net basis after adjusting the royalty paid against income from sub-licensing.( AY.2007-08 to 2011-12)