TMI Blog1986 (9) TMI 75X X X X Extracts X X X X X X X X Extracts X X X X ..... he Companies (Profits) Surtax Act, 1964. The reference relates to the assessment year 1968-69. The question referred to us for our opinion is as follows : "(1) Whether on the facts and in the circumstance of this case, the Tribunal were correct in law in holding that the entire amount of Rs. 5,02,654 was deductible for computing surtax liability ?" The assessee is a private limited company eng ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s thus deductible expense. In the case of surtax assessment, the assessee claimed deduction of the same sum of Rs. 5,02,654 on the footing that it was revenue expenditure and thus deductible from the income. The Income-tax Officer excluded a sum of Rs. 2,50,000 because a sum of Rs. 2,52,654 only had been debited in the books of account. The assessee had done so because he had already deducted a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he furnaces was revenue expenditure and was deductible as such, that opinion must prevail in the present case as well. The expenditure was obviously revenue in nature. That being so, it was a deductible expense. Following the view taken by this court in the aforesaid case CIT v. Seraikella Glass Works (P) Ltd. [1986] 157 ITR 584 (Pat), we hereby hold that on the facts and circumstances of the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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