Current repairs include replacement of worn-out subsidiary machine parts when ordinary wear and tear makes them unserviceable.

Expenditure on replacing cotton bowls in calendering machines was treated as current repairs because the bowls were only a subsidiary part of the machinery and were subject to ordinary wear and tear. The expression "current repairs" was held not to mean only petty repairs; it extends to replacement of a worn-out component needed to keep the machine serviceable. The replacement expense was therefore deductible as current repairs under section 10(2)(v) of the Indian Income-tax Act, 1922.

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Issues: Whether expenditure incurred for replacing cotton bowls in calendering machines constituted expenditure on current repairs deductible under section 10(2)(v) of the Indian Income-tax Act, 1922.

Analysis: The cotton bowl was found to be only a part of the calendering machine and not the entirety of the machinery. The evidence showed that the bowls were subject to constant wear and tear and had to be replaced when they became unserviceable. The expression "current repairs" was held not to be confined to petty repairs alone; its scope depends on the nature of the machinery and includes replacement of a subsidiary part worn out in the ordinary course of use. On the authority of the Supreme Court's decision in Mahalakshmi Textile Mills, replacement of a part of machinery due to wear and tear falls within current repairs.

Conclusion: The expenditure on replacing the cotton bowls was deductible as current repairs and was allowable under section 10(2)(v) of the Indian Income-tax Act, 1922.

Ratio Decidendi: Replacement of a worn-out subsidiary part of a machine, when necessitated by ordinary wear and tear, constitutes current repairs within the meaning of section 10(2)(v) of the Indian Income-tax Act, 1922.

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