1984 (3) TMI 34

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....d the above claim. The assessee went up in appeal before the AAC, which was dismissed. The assessee carried the matter in further appeal to the Income-tax Appellate Tribunal, Amritsar Bench. Before the Tribunal reliance was placed on a judgment of the Supreme Court in Bombay Steam Navigation Co. (1953) Private Limited v. CIT [1965] 56 ITR 52. In that case, revenue expenditure had been given the following definition (headnote): " In considering whether expenditure is revenue expenditure, the court has to consider the nature and the ordinary course of business and the objects for which the expenditure is incurred. The question whether particular expenditure is revenue expenditure incurred for the purpose of the business must be viewed in t....

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....riction was placed on the number of working hours per week for which the mills were entitled to work their looms. The working time agreement also provided that no signatory shall work for more than 45 hours per week and that the signatories to the agreement shall be entitled to transfer any part or wholly, their allotment of hours of work per week to any one or more of the other signatories. Under this agreement, the assessee in that case had purchased " loom hours " from two other mills for an aggregate sum of Rs. 2,03,255. This amount was claimed is revenue expenditure. When this controversy came up before the Supreme Court, speaking for the Bench, Bhagwati J. observed (p. 12): " We are conscious that in law as in life, and particularl....