B.N.KIRPAL, J. (1) DELAY condoned. (2) SPECIAL leave granted. (3) WE have heard the counsel for the parties. (4) IN our opinion, question of law definitely arose in this case. We, therefore, allow this appeal, direct the Tribunal to state the case and refer the following question of law to the High Court: "WHETHER on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the payment on account of technical know-how amounting to Rs 72,91,580.00 is allowable deduction as revenue expenditure under the Income Tax Act, 1961?"