Debenture issue not capital expenditure: prior ruling followed and assessee succeeded against Revenue.

Expenditure incurred on issue of debentures was held not to be capital expenditure. The appeals raised an identical question to one previously decided in favour of the assessee, so the same conclusion was applied here. The issue was answered in the negative, in favour of the assessee and against the Revenue, and the Tribunal's contrary view was not sustained.

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Issues: Whether the expenditure incurred on issue of debentures was capital expenditure.

Analysis: The question framed in these appeals was identical to the question decided earlier in favour of the assessee. On that basis, the answer to the present question was required to follow the same conclusion.

Conclusion: The question was answered in the negative, in favour of the assessee and against the Revenue; the Tribunal's view was not sustained.

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