https://www.taxtmi.com/caselaws?id=189729 Minimum royalty paid under mica mining leases was treated as capital expenditure, not revenue expenditure deductible under section 10(2)(xv) of the Income-tax Act, 1922. The mining venture had not yet yielded any income, and the material showed only preliminary prospecting operations. The mining activity was distinct from the assessee's existing purchase-and-sale business, and no substantive mining business had been established or carried on during the year. On those facts, expenditure incurred merely to preserve or safeguard the mining leases was not laid out wholly and exclusively for business purposes, and the distinction between setting up and commencement of business did not assist the assessee. The deduction was disallowed. en-us Tue, 17 Aug 1954 00:00:00 +0530 Wed, 18 Jan 2017 18:00:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=189729 Minimum royalty paid under mica mining leases was treated as capital expenditure, not revenue expenditure deductible under section 10(2)(xv) of the Income-tax Act, 1922. The mining venture had not yet yielded any income, and the material showed only preliminary prospecting operations. The mining activity was distinct from the assessee's existing purchase-and-sale business, and no substantive mining business had been established or carried on during the year. On those facts, expenditure incurred merely to preserve or safeguard the mining leases was not laid out wholly and exclusively for business purposes, and the distinction between setting up and commencement of business did not assist the assessee. The deduction was disallowed. Case-Laws Income Tax Tue, 17 Aug 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=189729