Current repairs under income-tax law exclude machinery replacement that fails the statutory test, consistent with prior Supreme Court rulings.

Expenditure on replacement of machinery is deductible as current repairs only if it satisfies the legal test under Section 31 of the Income-tax Act, 1961. The Supreme Court treated the issue as covered by its earlier rulings in Saravana Spg. Mills and Ramaraju Surgical Cotton Mills and disposed of the appeals consistently with those decisions. On that basis, the claim for deduction as current repairs was not accepted, and the Department's appeals were concluded in line with the Court's established interpretation of the scope of current repairs.

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Issues: Whether expenditure incurred on replacement of machinery is allowable as current repairs under Section 31 of the Income-tax Act, 1961.

Analysis: The issue was treated as covered by earlier decisions of the Court in Saravana Spg. Mills and Ramaraju Surgical Cotton Mills, and the appeals were disposed of in terms of those rulings.

Conclusion: The claim for deduction as current repairs was not accepted in these appeals.

Final Conclusion: The Department's appeals were concluded consistently with the Court's earlier rulings on the scope of current repairs under the income-tax law.

Ratio Decidendi: Expenditure on replacement of machinery is deductible only if it answers the legal test of current repairs under Section 31 of the Income-tax Act, 1961.

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