Document Fragment View

Matching Fragments

  Provision of (5 + 20 PMBX) board                       Rs. 
Annual rent for 5 + 20 PMBX board                   3,000-00
Installation charges                                  700-00
Annual rent for 1-5 Ø (1) @ 200                      3,000-00
Installation charges for 15 Øs @ 150                 2,250-00
Conversion of 3 direct lines into Jn. lines @ 100     300-00
                                                   ---------
(Rs. Nine thousand two hundred & fifty only)        9,250-00
                                                   ---------

 

Therefore, it is clear from above document of unimpeachable nature that the amount was not spent for getting any tangible asset of enduring nature to the assessee firm. On the other hand the amounts were representing annual rent payable, installation charges and conversion of direct lines into junction lines. In our opinion all these items represent only revenue expenditure and not one item of it represents capital expenditure. Lower Authorities had not the advantage of the documents now produced before us and therefore, on a misconception they held that the whole of Rs. 9,250 represents capital expenditure, simply because this item of Rs. 9,250 was entered under the head 'telephone deposit' in the accounts of the assessee firm. Therefore, the Lower Authorities held that this expenditure secures an enduring advantage to the assessee. But as we have seen from the cash bill the amount spent only mostly for yearly rent and hence revenue in nature. Therefore, the disallowance of Rs. 9,250, in our opinion, should be cancelled.