{"id":29651,"date":"1995-03-24T00:00:00","date_gmt":"1995-03-23T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/anil-dev-dass-vs-income-tax-officer-on-24-march-1995"},"modified":"2016-08-10T03:27:46","modified_gmt":"2016-08-09T21:57:46","slug":"anil-dev-dass-vs-income-tax-officer-on-24-march-1995","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/anil-dev-dass-vs-income-tax-officer-on-24-march-1995","title":{"rendered":"Anil Dev Dass vs Income-Tax Officer on 24 March, 1995"},"content":{"rendered":"
Income Tax Appellate Tribunal – Chandigarh<\/div>\n
Anil Dev Dass vs Income-Tax Officer on 24 March, 1995<\/div>\n
Equivalent citations: 1995 54 ITD 139 Chd<\/div>\n
Bench: J Kathuria, N Agrawal<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
J. Kathuria, Accountant Member <\/p>\n
1. This appeal by the assessee pertains to asst. year 1992-93. Ground No. 1 is against the confirmation of disallowance of Rs. 2,22,453.\n<\/p>\n
2. The assessee is an individual whose accounting period relevant to assessment year 1992-93 ended on 31 -3-1992. The assessee was carrying on tailoring business at the premises taken on lease from the Estate Office. To start with, the assessee was paying monthly rent of Rs. 400 which was unilaterally raised to Rs. 2,671 w.e.f. 1-3-1982. The assessee carried out repairs\/renovations and incurred a sum of Rs. 2,22,453. The details of these expenses are under the head “Renovation account” and are available at pages 7 and 8 of the assessee’s compilation. These are mostly cash payments in respect of certain bills.\n<\/p>\n
3. The Assessing Officer was of the opinion that these renovations carried out by the assessee resulted in enduring benefit to him and hence the entire expenditure was of capital nature. He, accordingly, disallowed a sum of Rs. 2,22,453 but directed the allowance of depreciation on the same. The learned CIT(A) upheld the action of the Assessing Officer.\n<\/p>\n
4. Shri B.S. Gupta, the learned Counsel for the assessee, submitted that the assessee was occupying a tenanted property, that the assessee was carrying on tailoring and draper’s business and that the assessee started selling ready-made shirts also which was part of the existing business. It was submitted that with the passage of time, certain parts of the building required urgent repairs because of wear and tear and since the Estate Office was not interested in doing the same, the assessee, with a view to developing and facilitating his business, carried out the necessary repairs which consisted of re-laying of broken floor, extension of mezzanine floor, provision of a false ceiling to give a good look, a slight shifting of staircase which already existed and provision of racks and almirahs. It was submitted that no new asset came into being and the assessee only gave a better look to its business premises to attract custom and cater to the taste of his clientele.\n<\/p>\n
5. Relying on the Supreme Court judgment in the case of Empire Jute Co. Ltd. v. CIT[ 1980] 124 ITR 1, it was submitted that the expenditure was incurred to run his existing business more efficiently and more profitably and hence the expenditure was revenue in nature. Relying on the Punjab and Haryana High Court judgment in the case of Allied Metal Products v. CIT[1982] 137 ITR 689, it was submitted that whether an expenditure is capital or revenue, has to be decided on the facts of each case and the question has to be determined in the environments of the business involved and the circumstances and the enduring nature is not the sole test to take the expenditure out of the ambit of a revenue expenditure. In that case also, the assessee carried on business in the premises taken on lease. The assessee had to keep those premises in a good condition and spent a sum of Rs. 22,301 on the repairs. The said expenditure was held to be revenue in nature.\n<\/p>\n
6. Reliance was placed on the Delhi High Court judgment in the case of Modi Spg. & Wvg. Mills Co. Ltd. v. CIT[l 993] 200 ITR 544. In that case also, building had been taken on lease for a limited period and the assessee incurred expenditure on fixing a false ceiling, painting and making some structural changes. It was held that the expenditure was deductible under Section 37(1) of the Act for facilitating carrying on of business.\n<\/p>\n
7. The learned counsel for the assessee also placed reliance on another decision of the Delhi High Court in the case of Instalment Supply (P.) Ltd v. CIT[ 1984] 149 ITR 52. In that case also, the assessee had taken premises on lease. The assessee spent a sum of Rs. 47,186 for re-designing, marble flooring, better fittings and wood work. The re-designing consisted of converting a large number of small rooms into one big hall more suited for office purposes and the expenditure included consultant fees to a structural engineer. A sum of Rs. 9,399 was considered by the assessee itself as capital expenditure and the balance of Rs. 37,787 was claimed as revenue expenditure. The High Court held that the assessee had obtained an advantage in a commercial sense by redesigning the premises and providing better fittings, better material and marble flooring and the advantage obtained by the assessee was for the purposes of the business of the assessee and not for the acquisition of a capital asset.\n<\/p>\n
8. The learned Counsel for the assessee also relied on the Allahabad High Court judgment in the case of Girdhari Dass & Sons v. CIT[1976] 105 ITR 339 for the proposition that when an owner incurs an expenditure on additions or alterations in a building which enhances its value, the expenditure can be of a capital nature but if a tenant incurs an expenditure on a rented building for its renovation or alteration, he does not acquire any capital asset because the building does not belong to him. Reliance was also placed on the Calcutta High Court judgment in the case of CIT v. Dewar’s Garage (India) (P.)Ltd [1993] 204 ITR 763. That was a case where the assessee being a tenant had received a demolition notice and had to carry out repairs to maintain structure and for that purposes had incurred an expenditure of Rs. 2,12,266, the said expenditure was held to be revenue expenditure because the renovation on re-conditioning was for maintaining the continuity of the business.\n<\/p>\n
9. The learned Counsel for the assessee also relied on another judgment of the Calcutta High Court in the case of Cultural Enterprises Corpn. v. CIT<\/a> [1992] 196 ITR 488. In that case also, the assessee had taken the premises on lease. The property taken on lease was in a dilapidated condition. Extensive repairs were done and a considerable expenditure incurred to bring the property to habitable condition. Sanitary fittings were replaced. The expenditure of Rs. 35,000 being expenditure on extensive repairs was held to be allowable as a deduction.\n<\/p>\n
10. The learned Counsel for the assessee further pointed out that the decision of the Allahabad High Court in the case of Kanpur Agencies (P.) Ltd. v. CIT[1968] 70 ITR 337 relied on by the learned CIT(A) in the instant case was not correctly decided. It was submitted that in that case, the amount of Rs. 9,560 spent on conversion of manual latrines into flush latrines and on replacing the tiled roofs of the labourers’ quarters by cement roofs was held to be an expenditure for bringing out a substantial improvement in the property and not for restoring to its original conditions. It was submitted that this decision was rendered on 12-7-1967 and that thereafter a lot of refinement has taken place and the courts have taken a liberal view rather than a strait-jacketed one.\n<\/p>\n
11. As regards the Delhi High Court decision in the case of Gurnarain Khanna & Sons v. CIT[ 1986] 159 ITR 231 also relied on by the learned CIT(A) in the instant case, it was submitted that that case was decided on different facts. It was submitted that in that case, the expenditure was incurred on providing a new urinal and errecting a new boundary wall. The learned Counsel for the assessee vehemently argued that so far as the instant case was concerned, the expenditure incurred on the premises taken on lease was only to run his business more efficiently and more profitably and that there was no enduring benefit accruing to the assessee from such expenditure.\n<\/p>\n
12. The learned D.R. submitted that the assessee had not given any breakup of the expenses as to how much was on fittings and furniture and how much on other things. It was submitted that the renovation account did not incorporate any details which could give the correct nature of the work done by the assessee. It was also submitted that the assessee previously was carrying on tailoring business and that he diversified his business by selling ready-made shirts also for which new look was given to the shop and renovations\/alterations made. According to the learned D.R., such renovation did result in a benefit of enduring nature and were capital in nature. It was pointed out that the two cases of Kanpur Agencies (P.) Ltd. (supra) and Gurnarain Khanna & Sons (supra) which had been referred to and relied on by the learned CIT(A) were not distinguishable on facts and that the ratio of those decisions applied with full force to the instant case as well.\n<\/p>\n
13. We have carefully considered the rival submissions as also the facts on record. Though the assessee has filed a copy of the renovation account, the details do not show as to the exact nature of the work done by the quantum thereof. We are, therefore, handicapped in giving a clear-cut finding in the instant case. Be that as it may, there is no getting away from the fact that the assessee’s premises were taken on lease from the Estate Officer. The initial rent was Rs. 400 per month which was raised to Rs. 2,671 per month and later to about Rs. 17,000 per month which was being disputed by the assessee. The assessee was already doing draping and tailoring business. The assessee started selling ready-made shirts from the next year. In our opinion, this was expansion of the same business and the case of ready-made shirts did not mean that the assessee had set up an altogether new business. The expenditure which had to be done purely for carrying out the necessary repairs was certainly admissible as an allowable expenditure and in this category would fall the re-doing of the flooring, the slight adjustment of mezzanine floor, the provision of false ceiling and the shifting of the stair-case. The case law cited by the learned Counsel for the assessee supports the assessee’s case that the expenditure incurred on the aforesaid items was basically by way of repairs and to give a new look to the business premises to suit the taste of the clientele and to attract better customer. This expenditure was not running the business more efficiently and more profitably. Since the premises did not belong to the assessee but had been taken on lease, the expenditure incurred on the aforesaid items is, therefore, held to be an expenditure of revenue nature and it would be allowable as a deduction. We hold and direct accordingly.\n<\/p>\n
14. From the discussion at the time of hearing, it appeared that the assessee had also prepared certain racks and almirahs, etc., which would not be an expenditure on repairs. The re-designing of counter already in existence would be an allowable expenditure but to provide a new counter altogether would be a capital expenditure. In the absence of details, we are not in a position to pin-point as to how much expenditure was incurred on providing racks and almirahs, etc. We, therefore, restore this matter to the Assessing Officer for the limited purposes of determining as to how much expenditure was incurred by the assessee on providing racks and almirahs, etc., which were items of fittings and furniture which would certainly be of a capital nature and not of revenue. For this limited purpose only the matter is being restored to the Assessing Officer, and the balance of the expenditure incurred by the assessee is held to be an allowable revenue expenditure.\n<\/p>\n
15. In arriving at the above conclusion, we have followed the later decisions of the various High Courts referred to by the learned Counsel for the assessee which have laid down a more pragmatic and practical approach than the decisions of the Allahabad and Delhi High Courts relied on by the learned CIT(A) in the impugned order.\n<\/p>\n
16. to 20. [These paras are not reproduced here, as they involve minor issues].<\/p>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Chandigarh Anil Dev Dass vs Income-Tax Officer on 24 March, 1995 Equivalent citations: 1995 54 ITD 139 Chd Bench: J Kathuria, N Agrawal ORDER J. Kathuria, Accountant Member 1. This appeal by the assessee pertains to asst. year 1992-93. Ground No. 1 is against the confirmation of disallowance of Rs. […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-29651","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nAnil Dev Dass vs Income-Tax Officer on 24 March, 1995 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/anil-dev-dass-vs-income-tax-officer-on-24-march-1995\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Anil Dev Dass vs Income-Tax Officer on 24 March, 1995 - 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