( 1 ) AT the instance of the Revenue, in respect of assessment year 1972-73, the following question has been referred by the Income Tax Appellate Tribunal. Delhi Bench, under Section 256 (1) of the Income Tax Act, 1961 (for short the Act), for the opinion of this Court:-

"whether on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the admission fee of Rs. 90,00 ( ). 00 paid by the assessee to M/s. Fractionisation Research Inc. was admissible as a revenue expenditure ?".

( 2 ) THE assessee is a public sector undertaking and derives income for supply of technical know-how to various concerns in India and abroad. It also undertakes turn key projects in India and abroad. During the previous year, ended on 31 March 1972 and relevant to the assessment year 1972-73, the assessee paid Rs. 90,000. 00 to M/s. Fractionisation Research Inc. as initial admission fee for its membership and claimed it as revenue expenditure. The said organisation is a cooperative research organisation and supplies to its members information concerning mathematical models which can be used for rational designing of vapour liquid contracting systems.

( 3 )