https://www.taxtmi.com/caselaws?id=168708 Expenditure on relaying and partly renewing worn railway rails and sleepers was treated as repair rather than capital reconstruction because it restored the line to its original condition without creating a new asset or materially improving the railway as a whole. The distinction between repair and renewal was applied flexibly: replacement of subsidiary parts in the course of ordinary maintenance can still qualify as revenue expenditure, while reconstruction of the entire undertaking is capital in nature. The taxpayer bears the burden of proving entitlement to the deduction, and that burden was satisfied on these facts. The cost was therefore deductible in computing taxable income under the relevant repairs provisions. en-us Fri, 13 Jan 1933 00:00:00 +0530 Mon, 23 Mar 2015 18:05:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168708 Expenditure on relaying and partly renewing worn railway rails and sleepers was treated as repair rather than capital reconstruction because it restored the line to its original condition without creating a new asset or materially improving the railway as a whole. The distinction between repair and renewal was applied flexibly: replacement of subsidiary parts in the course of ordinary maintenance can still qualify as revenue expenditure, while reconstruction of the entire undertaking is capital in nature. The taxpayer bears the burden of proving entitlement to the deduction, and that burden was satisfied on these facts. The cost was therefore deductible in computing taxable income under the relevant repairs provisions. Case-Laws Income Tax Fri, 13 Jan 1933 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168708