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1972 (7) TMI 7 - GUJARAT HIGH COURT
Assessee’s business of manufacture of scientific instruments and communication equipment - it cannot be said to have started until the necessary machinery were installed - obtaining of land and ordering for machinery, etc. were merely operations for setting up of the business - finding of the Tribunal that the business of the assessee was set up in the previous year that is, prior to 31st March, 1966, was contrary to evidence or based on no evidence at all. It was impossible for the Tribunal to have come to that decision on the facts found by it - revenue expenditure incurred prior to that date would not be permissible deduction