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10. The finding reached by the Tribunal was that no part of the surplus net income of the trust properties for the relevant previous years was utilised in constructing the new dharamshala and the new dharamshala was constructed out of the accumulations of past income. This findings was challenged on behalf of the trustees and their contention was that it was based on an erroneous inference drawn from the accounts maintained by the trustees. Now, it is clear from the judgment of the Tribunal that what strongly impressed the Tribunal in taking a view against the trustees was that the expenditure incurred by the trustees in constructing the new dharamshala was not debited to the profit and loss account. The argument which found favour with the Tribunal was that if the expenditure incurred by the trustees in constructing the new dharamshala had come out of the surplus net income of the trust properties for the relevant previous years, such expenditure could have been debited by the trustees to the profit and loss account, but that was not done in the present case and this circumstance went to show that no part of the surplus net income of the trust properties for the relevant previous years was utilised for the purpose of meeting such expenditure but it was paid out of the accumulations of past income. We cannot give our assent to this line of argument which found acceptance with the Tribunal. We fail to see how the Tribunal could draw an adverse inference against the trustees from the mere fact that expenditure on the construction of the new dharamshala was not debited in the profit and loss account. The expenditure incurred in constructing the new dharamshala, though undoubtedly expenditure for carrying out the dominant charitable purpose for which the trust properties were held by the trustees, was not revenue expenditure : it was expenditure for bringing into existence a capital asset : it did not go out of the books of account but was substituted by a capital asset. Such expenditure, obviously, could not be debited to the profit and loss account according to any recognised method of book-keeping even if it was made out of the net income of the trust properties for the relevant previous years. The only way in which such expenditure could be accounted for in the books of account was by showing it on the assets side of the balance-sheet and that is precisely what was done in the present case. The Tribunal was, therefore, clearly in error in taking the view that because the expenditure incurred in constructing the new dharamshala was not debited to the profit and loss account, it could not have come out of the net income of the trust properties for the relevant previous years. We think that, in the absence of any strong and cogent circumstance indicating that the new dharamshala was constructed out of the accumulations of past income, the normal presumption would be that the expenditure on the construction of the new dharamshala was made out of the net income of the relevant previous years except of course to the extent to which such expenditure was in excess of the net income. the revenue has not been able to point out any countervailing circumstance which would offset the weight of this presumption. The balance-sheets of the trust in fact show that the expenditure on the construction of the new dharamshala in samvat years 2017 and 2018, being the relevant previous years, could not have come wholly out of the trust properties for those Samvat years was utilised in constructing the new dharamshala. Take, for example, the year 2018. The amount expended by the trustees was Rs. 61,141.53. The balance-sheet of the trust for Samvat year 2018 shows that at the commencement of the year there was a balance of Rs. 2,34,132.14 to the credit of the income and expenditure account. That was the accumulation of past income but all of it was invested in the assets shown on the assets side of the balance-sheet for Samvat year 2017. Barring outstanding loans to the extent of Rs. 8,000 which seem to have been realised in Samvat year 2018, none of the other assets in which the accumulation of past income stood invested at the beginning of Samvat year 2018 was liquidated for the purpose of meeting the expenditure incurred in constructing the new dharamshala in Samvat year 2018. The balance-sheet for Samvat year 2018 shows that the trustees in fact borrowed an aggregate sum of Rs. 17,000 on interest-free loan in order to meet the expenditure of constructing the new dharamshala. The expenditure on constructing the new dharamshala thus came out of the net surplus income of Rs. 31,541.26, borrowing of Rs. 17,000 realisation of outstanding loans of Rs. 8,000 and recovery of some outstanding rent and part of cash and bank balance. The whole of the net surplus income of Rs. 31,541.26 was thus utilised in constructing the new dharamshala in Samvat year 2018. Similarly, a comparison of the balance-sheet for Samvat years 2016 and 2017 would show that the whole of the net surplus income of Rs. 35,298 was utilised in constructing the new dharamshala in Samvat year 2017. We must, therefore, reach the conclusion that the net surplus income of the trust properties for the relevant previous years was applied wholly in constructing the new dharamshala and the finding of the Tribunal to the contrary must be rejected.