1982 (2) TMI 58

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....s. 3,500. The agreement to lease was executed on 23rd June, 1964, whereas the deed of lease was executed on 2nd May, 1967. The lease was for an initial period of 20 years with an option for renewal granted to the lessee at a higher rent, as can be seen from cl. 5 of the lease deed dated 2nd May, 1967. It is common ground that the lease of the said premises was taken for the use thereof as business premises. For the relevant assessment year the assessee claimed an expenditure of Rs. 10,700 as expenditure incurred by way of registration fee, stamp duty and solicitors' fees in connection with the drawing up of the said deed of lease. In fact, it can be seen that out of the said amount the largest portion, viz., of Rs. 9,450, represents the amo....

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....ction is allowed in respect of any expenditure, not being in the nature of capital expenditure or personal expenses of the assessee, laid out or expended wholly and exclusively for the purposes of the business or profession of the assessee. This provision is in pari materia with a similar provision contained in s. 10(2)(xv) of the Indian I.T. Act, 1922. In CIT v. Hoechst Pharmaceuticals Ltd. [1978] 113 ITR 877, it was held by a Division Bench of this court that expenses incurred by way of brokerage and stamp duty for acquiring office premises on lease for short period of five years are allowable deductions in computing the total income of the assessee, since the period of the lease could not be said to be such a long period that the asse....