TMI Blog1985 (9) TMI 42X X X X Extracts X X X X X X X X Extracts X X X X ..... at the instance of the Revenue. It poses the following two questions : " (1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the interest paid on withdrawals used for the purpose of the payment of dividend was a revenue expenditure ? (2) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the exp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... diffuser working ". The Income-tax Officer disallowed the expenditure for both the years on the ground that the expenditure was of a capital nature. The Appellate Assistant Commissioner, in appeal, agreed with the Income-tax Officer that the tours were made not only for study but also for the purchase of a capital asset. He directed the Income-tax Officer to capitalise the expenditure for the pur ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... development rebate could be allowed on that extent of the expenditure which related to the study of the working of the diffuser. The capital asset which was purchased was a diffuser and this is clear from a reference to the question and the order of the Appellate Assistant Commissioner for the assessment year 1968-69. The entire expenditure on foreign tours was, therefore, incurred in connection ..... X X X X Extracts X X X X X X X X Extracts X X X X
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