1985 (9) TMI 42

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....er section 256(1) of the Income-tax Act, 1961, made at the instance of the Revenue. It poses the following two questions : " (1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the interest paid on withdrawals used for the purpose of the payment of dividend was a revenue expenditure ? (2) Whether, on the facts and in the circumstances of the....

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.... the purchase of capital asset as also for the study of diffuser working ". The Income-tax Officer disallowed the expenditure for both the years on the ground that the expenditure was of a capital nature. The Appellate Assistant Commissioner, in appeal, agreed with the Income-tax Officer that the tours were made not only for study but also for the purchase of a capital asset. He directed the Incom....

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....ased was not a diffuser in which case no depreciation or development rebate could be allowed on that extent of the expenditure which related to the study of the working of the diffuser. The capital asset which was purchased was a diffuser and this is clear from a reference to the question and the order of the Appellate Assistant Commissioner for the assessment year 1968-69. The entire expenditure ....