1972 (2) TMI 31

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....J.-This reference under section 256(1) of the Income-tax Act of 1961, at the instance of the assessee, is to answer the question : " Whether, on the facts and in the circumstances of the case, the expenditure was a capital expenditure or a revenue expenditure? " The expenditure referred to is a sum of Rs. 10,370 incurred in connection with one of the directors of the assessee-company, one G.....

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....t the expenditure now incurred in financing the tour of a director to Japan is not in connection with any of these businesses that the company is already carrying on and will not enter into the ascertainment of trading profits connected therewith but it is in connection with a new business that they are seeking to start with Japanese collaboration. It is not enough if the articles sought to be man....

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....have brought them benefit of an enduring nature. Even intangible initial outlay for the initiation of a new line of business, when the business is started, would be of enduring benefit to the assessee. It is, therefore, in the nature of capital expenditure and not revenue expenditure. We, therefore, in the view that what they sought to start was a new line of business, are of the opinion that the ....