1985 (6) TMI 70

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..... 2 in respect of planting of trees in avenues in the industrial estate. The ITO disallowed the same as capital expenditure which was upheld on appeal by the Commissioner (Appeals). The learned counsel for the assessee submitted that the expenditure incurred did not result in the creation of any asset and it did not derive any benefit of enduring nature. Hence, it should be allowed as revenue expend .....

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..... penditure may nonetheless be on revenue account and the test of enduring benefit may break down. What is material to consider is the nature of the advantage in a commercial sense and it is only where the advantage is in the capital field that the expenditure would be disallowable on application of this test. The above ratio squarely applies to the instant case. No income-yielding capital asset has .....

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