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The High Court of Calcutta ruled in favor of the assessee, allowing the expenditure of Rs. 78,000 for converting oil-firing equipment to coal-firing as revenue expenditure under section 37(1) of the Income-tax Act, 1961. The Tribunal's decision was upheld as the conversion was for better operation of the machine and did not involve creating new plant or machinery. The question of law was answered in favor of the assessee, with no order as to costs.
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