1981 (1) TMI 129

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... he furtherance of the existing business. The ITO had found that the assessee had claimed Rs. 10,000 as travelling expenses for visit to Japan. It was explained before him that the assessee wanted to establish a manufacturing unit with foreign collaboration for manufacturing of Gaskets which is one of the important motor parts. For this purpose there was proposal for collaboration with Japan. It wa .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... submitted before us by Shri Tandan, the ld. Rep. of the assessee, that the assessee was dealing in motor parts and when he wanted to manufacture Gaskets the expenditure incurred in the course of concluding a foreign collaboration agreement should have been allowed as a revenue expenditure. For this reliance was placed on the decision of the Allahabad High Court in (1970) 78 ITR 766 (All) and Bomb .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... onsidered the facts of the case and we are of the view that the claim of the assessee cannot be accepted. From the facts it clear that the assessee was desirous of establishing a new business for manufacture of Gaskets and in that connection certain preliminary expenses had been incurred to explore the possibility of foreign collaboration for such manufacturing activity. This did not result into a .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X