In the field of biotechnology, license fee paid for acquiring genetic material for cereals, seeds, etc. along with right to future development and improvement and such technology would benefit assessee even after expiry of agreement period and even assessee could sell germplasm, a part of expenditure paid by assessee would be apportioned as capital expenditure. SC in Alembic Glass Company 177 ITR 377 had said that having regard to fast changing technology, there is not enduring benefit. However , Andhra Pradesh High Court in Advanta India Ltd pronounced on OCTOBER 9, 2015 [2015] 62 taxmann.com 223 (Andhra Pradesh) has found the Alembic Glass Company distinguishable.