RAJENDRA KUMAR BACHHAWAT Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) The assessee paid a sum of Rs. 25 lakhs for development purposes for the purpose of becoming a member of the Calcutta Stock Exchange. In the assessment years in question, viz., 1992-93, 1993-94, the assessee made two types of claims in regard to the said sum.

(2.) First, the assessee's contention was that the amount is by way of revenue expenditure and is not by way of capital expenditure.

(3.) Secondly, the assessee submitted that it was entitled to dissect the revenue expenditure of Rs. 25 lakhs, into 10 equal parts of Rs. 2,50,000 each, and claim deduction thereof in 10 successive assessment years, of which the two assessment years in question were the first two.