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Stamp duty and registration charges incurred for executing a lease deed may constitute revenue expenditure where the arrangement grants only a right to occupy, use, and commercially exploit property during the lease term, rather than ownership or an independent capital asset. The expenditure is deductible in full in the year when the lease rights and obligations crystallise; later registration does not change its character or timing. On the stated facts, the stamp duty was therefore allowable in A.Y. 2011-12. Because the full amount was deductible in that year, it could not subsequently be capitalised, amortised over the lease term, or subjected to depreciation, making later-year depreciation claims unsustainable.
Stamp duty and registration charges incurred for executing a lease deed may constitute revenue expenditure where the arrangement grants only a right to occupy, use, and commercially exploit property during the lease term, rather than ownership or an independent capital asset. The expenditure is deductible in full in the year when the lease rights and obligations crystallise; later registration does not change its character or timing. On the stated facts, the stamp duty was therefore allowable in A.Y. 2011-12. Because the full amount was deductible in that year, it could not subsequently be capitalised, amortised over the lease term, or subjected to depreciation, making later-year depreciation claims unsustainable.
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