( 1 ) THE assessee, the State Trading Corporalion of India Limited, a Government Company, incorporated under the Companies Act, 1956, was engaged during the assessment year 1962-63 for which the previous year ended on March 31, 1962, in amongst its other trading activities, the export of low grade iron ore. Supplies were procured from private mine owners. Some of these supplies were to be procured and shipped from the port of Redi in Maharashtra. The present controversy revolves round the assessee s claim for two of his expenditure items mentioned hereinafter, being allowed as revenue expense. The first item relate to the assessee s proposal to construct a building at Lodi Road, which, however, had to be abandoned as the land meant for the building was acquired by the Government. All the same, the assessee had to pay a sum of Rs. 10,000. 00 to Messrs LUC Durrant, Architects, for the preparation of the plan and construction of the building. The assessee claimed this to be revenue expenditure, but the Income-tax officer rejected this claim. The second item relates to the payment by the assessee of a sum of Rs. 2,00,000. 00 to the Maharashtra Government as grant for the de