Revenue expenditure on temporary roads and culvert for seasonal business transport was deductible because no enduring asset was created.

Expenditure incurred to construct temporary kachcha roads and a culvert for seasonal transport of sugarcane was held to be revenue in nature because it was laid on public land, became unusable after the season, and created no enduring asset or advantage. The court treated the recurring business necessity and the verifiable factual basis as decisive, and allowed deduction under section 10(2)(xv) of the Indian Income-tax Act, 1922.

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Issues: Whether the expenditure incurred on constructing kachcha roads and a temporary culvert was revenue expenditure deductible under section 10(2)(xv) of the Indian Income-tax Act, 1922.

Analysis: The expenditure was incurred to facilitate the seasonal movement of sugarcane to the factory and was supported by receipts and surrounding circumstances showing that it was verifiable. The roads and culvert were temporary in character, laid on public land, and became unusable after the season with rains and floods. No asset or advantage of an enduring nature was brought into existence, and the expenditure had to be incurred from year to year to meet business needs.

Conclusion: The expenditure was revenue in nature and was admissible as a deduction under section 10(2)(xv) of the Indian Income-tax Act, 1922.

Final Conclusion: The reference was answered in favour of the assessee, holding the impugned expenditure to be deductible revenue expenditure.

Ratio Decidendi: Expenditure incurred repeatedly for temporary business without creating an enduring asset or advantage is revenue expenditure, even if it results in construction work of a short-lived and practical utility.

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