2000 (11) TMI 24

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....the Revenue, it is contended that the contribution made by the assessee to the Government for building a new bridge in place of the old one which had become unserviceable, and which bridge was essential to provide access to the assessee's factory-as the workmen could not reach the factory unless that bridge was available for their movement is in the nature of capital expenditure, and not revenue a....

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....ered by a three-judge Bench of the apex court. Counsel for the Revenue, however, relied upon a decision rendered by a two-judge Bench of the apex court in the case of Arivind Mills Ltd. v. CIT [1992] 197 ITR 422, wherein it was held that the betterment charges paid by the mill in respect of the lands owned by it was a payment which was in the capital field, and not revenue, as the improvement e....