CIT v. Sri Mangayarkarasi Mills (P) Ltd.

315 ITR 114Supreme Court of India2009#2420 most cited

What is CIT v. Sri Mangayarkarasi Mills (P) Ltd. authority for?

Expenditure qualifies as 'current repairs' if it maintains existing machinery without replacement, creates no new asset, restores functional efficiency without increasing capacity, and is not an independent unit. Conversely, the cost of replacing machinery, especially independent units, constitutes capital expenditure.

48

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2011 to 2025.

Also referred to as

CIT v Sri Mangayarkarasi Mills · 315 ITR 114 · Section 30 Income Tax Act · Section 31 Income Tax Act · Section 37(1) Income Tax Act · current repairs vs capital expenditure · replacement of machinery · tests for current repairs · machinery replacement deduction · business expenditure classification

Sections most often in play

Section 143(3)Section 30Section 31Section 35Section 35ASection 35ESection 37Section 37(1)

Judgments citing CIT v. Sri Mangayarkarasi Mills (P) Ltd.

THE KERALA MINERALS AND METALS LIMITED,KOLLAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, KOLLAM

In the result, the appeal filed by the assessee stands partly allowed

ITA 918/COCH/2024[2007-08]Status: DisposedITAT Cochin16 May 2025AY 2007-08

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am Assessment Year: 2007-08 The Kerala Minerals & Metals Ltd. .......... Appellant Sankaramangalam, Chavara, Kollam 691583 [Pan: Aaact8118R] Vs. Asst. Commissioner Of Income Tax .......... Respondent Circle - 1, Kollam Appellant By: Shri Rajeev R., Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.05.2025 Date Of Pronouncement: 16.05.2025

For Appellant: Shri Rajeev R., CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)

…g Mills Ltd. (supra) categorically held that the expenditure incurred by the assessee towards replacement of machinery with new machinery constitutes a capital expenditure. Even the Hon’ble Supreme Court in the case of CIT vs. Sri Mangayarkarasi Mills P. Ltd, 315 ITR 114 5 The Kerala Minerals and Metals Ltd. held that each machinery which functions independently should be treated as such not as a mere part of any composite machinery of the plant. The said decisions had been considered by the Hon’ble Madras High Court in the case of Elgi Equipments Ltd. vs. JCIT, 120 taxmann.com 142 and laid down the following p…

NAGREEKA EXPORTS LIMITED vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-6, KOLKATA & ORS.

The Appeal is dismissed

ITA/373/2009HC Calcutta27 Feb 2024

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani & The Hon’Ble Justice Rajarshi Bharadwaj Date : 27Th February 2024. Appearance: Mr. Ranjeet Kr. Murarka, Advocate Mr. S.D. Verma, Advocate Mr. Ananda Sen, Advocate Mr. Vivek Murarka, Advocate … For The Appellant. Mr. S. Roychowdhury, Advocate Mr. Soumen Bhattacharjee, Advocate … For The Respondents 1. Heard Sri Ranjeet Murarka, Learned Counsel For The Appellant Assessee & Sri S. Roychowdhury, Learned Senior Standing Counsel For The Respondents. 2. This Appeal Was Admitted By This Court By Order Dated 04.02.2010, On The Following Substantial Questions Of Law:- “I. Whether On The Facts & Circumstances Of The Case The Order Of The Tribunal Is Erroneous As Being Perverse In Reversing The Order Of

Section 37Section 37(1)

…rred for replacement of ring frames is a revenue expenditure liable for deduction under Section 37 of the Act 1961. He submits that the judgment of Hon'ble Supreme Court in the case of Commissioner of Income Tax v. Sri Mangayarkarasi Mills (P) Limited [2009] 315 ITR 114 (SC) is not applicable inasmuch as in subsequent judgment in Commissioner of Income Tax v. Hindustan Textiles [2010] 190 Taxman 294 (SC) [paragraph 6], Hon'ble Supreme Court directed the High Court to consider the tests laid down in Commissioner of Income Tax v. Sugavaneeshwara Spinning Mills Ltd. 293 ITR 20 (SC), Commissioner of Income Tax v. Ra…

M/S. TANFAC INDUSTREIS LTD.,,CHENNAI vs. ACIT, CORPORATE CIRCLE - 3 (1),, CHENNAI

In the result, the appeal stands dismissed

ITA 719/CHNY/2020[2003-04]Status: DisposedITAT Chennai04 Jan 2023AY 2003-04

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R.Vijayaraghavan, (Advocate)- Ld. ARFor Respondent: Shri D.Hema Bhupal (JCIT)-Ld. DR
Section 143(3)

…the file of Ld. CIT(A) as under: - “6. We have perused the orders and heard the rival contentions. The case of Ramaraju Surgical Cotton Mills (supra), was considered by the Hon'ble Apex Court again in the case of CIT v. Sri Mangayarkarasi Mills P. Ltd. (2009) 315 ITR 114 (SC) and after referring to the decision of Ramaraju Surgical Cotton Mills (supra) as well as that of CIT v. Saravana Spinning Mills (P) Ltd. 293 ITR 201 (SC), remitted the matter back to the jurisdictional High Court for considering whether the claim of the assessee could be allowed based on the principles laid down in the above mentioned decisi…

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

ITA 1770/AHD/2012[2004-05]Status: DisposedITAT Ahmedabad26 May 2022AY 2004-05

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: 22-04-2022For Respondent: Shri Mohd. Usman, CIT DR &
Section 115J

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

ITA 1826/AHD/2010[2005-06]Status: DisposedITAT Ahmedabad26 May 2022AY 2005-06

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: 22-04-2022For Respondent: Shri Mohd. Usman, CIT DR &
Section 115J

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

GUJARAT INDUSTRIES POWER CO.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

ITA 1485/AHD/2010[2005-06]Status: DisposedITAT Ahmedabad26 May 2022AY 2005-06

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: 22-04-2022For Respondent: Shri Mohd. Usman, CIT DR &
Section 115J

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

THE DY. CIT., CIRCLE-1(1)(1),, VADODARA vs. M/S. GUJARAT INDUSTRIES POWER CO. LTD.,, VADODARA

In the result, the captioned appeals are :

ITA 2463/AHD/2016[2012-13]Status: HeardITAT Ahmedabad13 Apr 2022AY 2012-13

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Respondent: Shri Mohd. Usman, CIT DR
Section 115JSection 147Section 14ASection 80I

…iness of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court ITA Nos. 472/Ahd/2013 & Ors. (Gujarat Industrial Power Co. Ltd. ) - 13 - relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

THE DCIT, CIRCLE-1(1),, VADODARA vs. M/S. GUJARAT INDUSTRIES POWER CO.LTD.,, VADODARA

In the result, the captioned appeals are :

ITA 1257/AHD/2015[2011-12]Status: HeardITAT Ahmedabad13 Apr 2022AY 2011-12

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Respondent: Shri Mohd. Usman, CIT DR
Section 115JSection 147Section 14ASection 80I

…iness of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court ITA Nos. 472/Ahd/2013 & Ors. (Gujarat Industrial Power Co. Ltd. ) - 13 - relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

GUJARAT INDUSTRIES POWER CO. LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

In the result, the captioned appeals are :

ITA 535/AHD/2014[2010-11]Status: HeardITAT Ahmedabad13 Apr 2022AY 2010-11

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Respondent: Shri Mohd. Usman, CIT DR
Section 115JSection 147Section 14ASection 80I

…iness of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court ITA Nos. 472/Ahd/2013 & Ors. (Gujarat Industrial Power Co. Ltd. ) - 13 - relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

PAB ORGANICS PVT. LTD.,,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, VADODARA

In the result, the appeal of the assessee is allowed

ITA 2648/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad16 Mar 2022AY 2012-13

Bench: S/Shri Pramod M. Jagtap & T.R. Senthil Kumarassessment Year :2012-13 Pab Organics P.Ltd. Dcit, Cir.2(1)(2) 904-905, Atlantis Heights Vs Vadodra. Dr.Vikram Sarabhai Marg Wadi Wadi Vadodara 390 023. Pan: Aabcp 8169 R अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.Ki. Parikh, Ca Revenue By : Shri V.K. Singh, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 24/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 16 /03/2022 आदेश/O R D E R Per T.R. Senthil Kumar: This Appeal Is Filed By The Assessee Against Order Dated 25.07.2016 Passed By Ld.Commissioner Of Income-Tax (Appeals)-2, Vadodara [For Short “Ld.Cit(A)] In Appeal No.Cab/2/039/15-16 Relating To The Assessment Year 2012-13. 2. The Assessee Has Raised Mainly Two Issues, Viz. Disallowance Of Maintenance Expenditure To Plant & Machinery & Disallowance Of Foreign Travelling Expenses. These Issues Reflected In The Grounds Of Appeal Are As Follows: 2

For Appellant: Shri D.KI. Parikh, CAFor Respondent: Shri V.K. Singh, Sr.DR
Section 143(2)

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure." 10. The…

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

In the result, the captioned appeals are

ITA 3003/AHD/2010[2003-04]Status: DisposedITAT Ahmedabad28 Feb 2022AY 2003-04

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Marfatia, Shri Nirmit Mehta &For Respondent: Shri Mohd. Usman, CIT DR
Section 14ASection 234BSection 234CSection 271(1)(c)Section 801ASection 80I

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

THE DCIT, CIRCLE-1(1),, BARODA vs. M/S. GUJARAT INDUSTRIAL POWER CO.LTD.,, BARODA

In the result, the captioned appeals are

ITA 1534/AHD/2009[2005-06]Status: DisposedITAT Ahmedabad28 Feb 2022AY 2005-06

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

For Appellant: Marfatia, Shri Nirmit Mehta &For Respondent: Shri Mohd. Usman, CIT DR
Section 14ASection 234BSection 234CSection 271(1)(c)Section 801ASection 80I

…are of recurring nature and essentially required for smooth running of business of the assessee i.e, generation of power. The other decision of the Hon’ble Supreme Court relied upon by the learned D.R. in the case of CIT V/s. Sri Mangayarkarasi Mills (P) Ltd. 315 ITR 114 also following the decision in the case of CIT V/s. Saravana Spinning Mills (supra), has laid down the same proposition of law. On the other hand, the decisions relied upon by the assessee as noted in the order of the CIT(A) clearly supports the view that the expenditure incurred by the assessee cannot be treated as capital expenditure. In the af…

ACIT, COIMBATORE vs. SPACE TEXTILES PVT LTD, COIMBATORE

In the result, the appeal filed by the Revenue is dismissed

ITA 3488/CHNY/2018[2013-14]Status: DisposedITAT Chennai15 Feb 2022AY 2013-14

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri P. Sajit Kumar, JCITFor Respondent: Shri M. Sanjeev Aditya, CA
Section 143(3)

…essee claimed replacement expenses of Rs.1,65,28,800/- on account of purchasing of Elite Compact System and claimed the same as revenue expenditure. The AO relying on the Supreme Court judgment in the case of CIT vs. Sri Mangayarkarasi Mills (P.) Ltd., [2009] 315 ITR 114, noted that the compact spinning system introduced by the assessee in manufacturing process of yarn is state of art technology which is added to the existing machinery and this system has given advantage of enduring nature with the introduction of new technology and hence, the same is capital in nature. The AO after capitalizing the same allowed…

M/S RATNA CAFE,CHENNAI vs. ACIT NON CORPORATE CIRCLE 9, CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 1509/CHNY/2018[2009-10]Status: DisposedITAT Chennai21 Jan 2022AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 154

…ssee has capitalized the acquisition of new kitchen equipments, but for calculating total income, they have taken it as a revenue expenses to reduce their tax liability. The decision the Hon’ble Supreme Court in the case of M/s.Sri Mangayarkarasi Mills P Ltd [315 ITR 114(SC)] is squarely applicable in this case, wherein the court has observed that: “it was clear from record that the assessee has sought to treat the said expenditure differently for the purpose of computing its profit and for the purpose of payment of Income Tax. The said expenditure had been treated as an addition to the existing assets in the for…

DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED , HYDERABAD

Appeals are dismissed

ITA 678/HYD/2019[2016-17]Status: DisposedITAT Hyderabad16 Jul 2021AY 2016-17

Bench: Shri S.S. Godara & Shri L.P. Sahu

For Appellant: Sri Y. Ratnakar, A.RFor Respondent: Smt. N. Esther, D.R
Section 143(3)Section 234B

…tors Ltd. reported in 364 ITR 1 @ pages 11 to 14. The said decision fully supports the appellant's claim. 12. Reference is made by the learned Assessing Officer to a decision of the Hon'ble Supreme Court in CIT Vs. Mangayakrai Kasi Mills Pvt. Ltd. reported in 315 ITR 114. The facts of this case have no relevance at all to the facts on hand. The decision of the Hon'ble Supreme Court pertained to several items of plant and machinery which have been replaced. The old machinery was replaced by the new machinery as a result of which a new asset came into existence in the place of one. This was not a repair of old or t…

INCOME TAX OFFICER, WARD-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED , HYDERABAD

Appeals are dismissed

ITA 483/HYD/2019[2014-15]Status: DisposedITAT Hyderabad16 Jul 2021AY 2014-15

Bench: Shri S.S. Godara & Shri L.P. Sahu

For Appellant: Sri Y. Ratnakar, A.RFor Respondent: Smt. N. Esther, D.R
Section 143(3)Section 234B

…tors Ltd. reported in 364 ITR 1 @ pages 11 to 14. The said decision fully supports the appellant's claim. 12. Reference is made by the learned Assessing Officer to a decision of the Hon'ble Supreme Court in CIT Vs. Mangayakrai Kasi Mills Pvt. Ltd. reported in 315 ITR 114. The facts of this case have no relevance at all to the facts on hand. The decision of the Hon'ble Supreme Court pertained to several items of plant and machinery which have been replaced. The old machinery was replaced by the new machinery as a result of which a new asset came into existence in the place of one. This was not a repair of old or t…

DCIT, CIRCLE-2(2), HYDERABAD, HYDERABAD vs. GLOBAL ALUMINIUM PVT. LTD., SECUNDERABAD, SECUNDERABAD

Appeals are dismissed

ITA 968/HYD/2017[2012-13]Status: DisposedITAT Hyderabad16 Jul 2021AY 2012-13

Bench: Shri S.S. Godara & Shri L.P. Sahu

For Appellant: Sri Y. Ratnakar, A.RFor Respondent: Smt. N. Esther, D.R
Section 143(3)Section 234B

…tors Ltd. reported in 364 ITR 1 @ pages 11 to 14. The said decision fully supports the appellant's claim. 12. Reference is made by the learned Assessing Officer to a decision of the Hon'ble Supreme Court in CIT Vs. Mangayakrai Kasi Mills Pvt. Ltd. reported in 315 ITR 114. The facts of this case have no relevance at all to the facts on hand. The decision of the Hon'ble Supreme Court pertained to several items of plant and machinery which have been replaced. The old machinery was replaced by the new machinery as a result of which a new asset came into existence in the place of one. This was not a repair of old or t…

DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2), HYDERABAD vs. GLOBAL ALUMINIUM PRIVATE LIMITED, SECUNDERABAD

Appeals are dismissed

ITA 1374/HYD/2017[2013-14]Status: DisposedITAT Hyderabad16 Jul 2021AY 2013-14

Bench: Shri S.S. Godara & Shri L.P. Sahu

For Appellant: Sri Y. Ratnakar, A.RFor Respondent: Smt. N. Esther, D.R
Section 143(3)Section 234B

…tors Ltd. reported in 364 ITR 1 @ pages 11 to 14. The said decision fully supports the appellant's claim. 12. Reference is made by the learned Assessing Officer to a decision of the Hon'ble Supreme Court in CIT Vs. Mangayakrai Kasi Mills Pvt. Ltd. reported in 315 ITR 114. The facts of this case have no relevance at all to the facts on hand. The decision of the Hon'ble Supreme Court pertained to several items of plant and machinery which have been replaced. The old machinery was replaced by the new machinery as a result of which a new asset came into existence in the place of one. This was not a repair of old or t…

JAYA HIND INDUSTRIES LIMITED,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 9,, PUNE

In the result, the appeal filed by the assessee stands allowed

ITA 2149/PUN/2017[2010-11]Status: DisposedITAT Pune04 Jan 2021AY 2010-11
For Appellant: Shri Mukesh PatelFor Respondent: Shri Sudhendu Das
Section 143(2)Section 143(3)Section 31

…g Mills Ltd. (supra) categorically held that the expenditure incurred by the assessee towards replacement of machinery with new machinery constitutes a capital expenditure. Even the Hon’ble Supreme Court in the case of CIT vs. Sri Mangayarkarasi Mills P. Ltd, 315 ITR 114 held that each machinery which functions independently should be treated as such not as a mere part of any composite machinery of the plant. The said decisions had been considered by the Hon’ble Madras High Court in the case 4 of Elgi Equipments Ltd. vs. JCIT, 120 taxmann.com 142 and laid down the following principles :- “17. A careful look at t…

DCIT LTU, MUMBAI vs. BAJAJ HOLDING & INVESTMENTS LTD, MUMBAI

In the result, all the appeals filed by the revenue are dismissed

ITA 6963/MUM/2014[1993-94]Status: DisposedITAT Mumbai28 Aug 2020AY 1993-94

Bench: Shri M.Balaganesh, Am & Shri Ram Lal Negi, Jm

Section 143(3)Section 254

…Court considered the decisions in the case of CIT Vs. Saravana Spinning Mills P; Ltd., reported in (2007) 293 ITR 201 (SC), CIT Vs. Ramaraju Surgical Cotton Mills reported in (2007) 294 ITR 328 (SC) and CIT Vs. Mangayarkarasi Mills P.Ltd., reported in (2009) 315 ITR 114 (SC) and pointed out that the question as to whether the expenditure incurred on replacement of machinery is revenue or capital rests on the nature of capital incurred vis-a-vis the benefit derived. This M/s.Bajaj Holdings & Investment Ltd., (Formerly known as Bajaj Auto Ltd.,) Court referred to the decision in the case of CIT Vs. Saravana Spinn…

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