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TMI Blog2008 (7) TMI 394X X X X Extracts X X X X X X X X Extracts X X X X ..... laying road and also a Government of Tamil Nadu company incorporated as a nodal agency for implementation of the Industrial Policy in the State of Tamil Nadu and for creation of infrastructure facilities such as road system highways bridge projects in the State on a commercial frame work. On the abovesaid finding of fact, the Commissioner (Appeals) has come to the conclusion that those expenses c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ormulated in this appeal are as follows: "1. Whether, on the facts and circumstances of the case, the Tribunal was right in deleting the disallowance made by the Assessing Officer towards expenditure incurred by the assessee on techno-economic feasibility report for the manufacture of the new product ? 2. Whether, on the facts and circumstances of the case, expenses related to feasibility stud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Corporation Ltd. (No. 1) [1990] 182 ITR 62, allowed the appeal in favour of the assessee. The appeal preferred by the Revenue to the Tribunal ended in dismissal. Aggrieved by the same, the present appeal is filed. 3. The Commissioner of Income-tax (Appeals) has recorded a finding that various expenses claimed by the assessee have been incurred on various test studies, feasibility reports, p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t of the provisions of section 35D because these have not been incurred for the expansion or extension of business but merely to find out new ideas by conducting test studies and pilot studies for improving the existing business. On those facts and relying on a decision of this court in the case of CIT v. Seshasayee Brothers P. Ltd. [1981] 127 ITR 218 and that of the Kerala High Court in CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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