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Issues:
1. Entitlement to relief under section 84 of the Income-tax Act, 1961. 2. Allowability of specific sums as revenue expenditure for the assessment year 1963-64. Analysis: 1. The judgment addressed the issue of whether the assessee was entitled to relief under section 84 of the Income-tax Act, 1961. Referring to a previous unreported decision and following established precedents, the court answered this question in the affirmative and in favor of the assessee. The decision was based on legal interpretations and previous court rulings, providing a clear resolution to this issue. 2. Regarding the specific sums claimed as revenue expenditure for the assessment year 1963-64, the judgment considered three items: (a) expenditure incurred in connection with the foundation laying ceremony, (b) expenditure on printing additional articles of association, and (c) legal expenses related to the alteration of the articles of association. The court found that items (b) and (c) were already concluded by previous decisions and were to be answered affirmatively in favor of the assessee without the need for detailed elaboration. 3. The court then focused on item (a) of question No. (2), which involved expenditure on the foundation laying ceremony of a new plant. The assessee had incurred various costs for the ceremony, and the issue was whether this expenditure could be allowed as revenue expenditure. The Income Tax Officer (ITO) initially disallowed it, but the Appellate Authority Commissioner (AAC) and the Tribunal disagreed, allowing the expenditure as it was incurred in the course of the assessee's business. The court referenced decisions from the Madras High Court and a previous Bombay High Court case to support the conclusion that such expenditure could be considered revenue expenditure. Therefore, the court concurred with the Tribunal's finding on this item as well. 4. Ultimately, the judgment answered all three items (a), (b), and (c) of question No. (2) in the affirmative and in favor of the assessee. The decision was based on a thorough analysis of the facts, legal interpretations, and precedents cited during the proceedings. The parties were directed to bear their own costs, concluding the legal judgment delivered by the Bombay High Court.
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