Interior decoration in leased premises found non-capital in nature, with no substantial question of law arising on appeal.

Interior decoration works in leased premises for a branded showroom were found, on concurrent factual findings, not to have created any enduring benefit or capital asset in favour of the assessee. On that basis, the claim to 100% depreciation was assessed against the factual record rather than any disputed legal principle, and the Court held that no substantial question of law arose for consideration in the appeals. The tax case appeals were therefore dismissed.

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Issues: Whether the assessee was entitled to 100% depreciation on interior decoration work carried out in leased premises and whether the appeal raised any substantial question of law.

Analysis: The disputed expenditure related to interior works, including fittings and partitions, undertaken to set up a branded showroom in leased premises. The factual finding recorded in the appellate orders was that the works were carried out according to the brand specifications and did not result in any enduring benefit or creation of a capital asset in favour of the assessee. The Court held that the challenge was essentially factual and that no substantial question of law arose for consideration in the appeals.

Conclusion: The assessee was not entitled to interfere with the concurrent factual findings, and the appeals failed.

Final Conclusion: The interior decoration expenditure was treated as not giving rise to a substantial question of law, and the tax case appeals were dismissed.

Ratio Decidendi: Concurrent factual findings that interior works in leased premises do not create an enduring capital asset do not give rise to a substantial question of law in appeal.

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