( 1 ) THE short question arising in this reference is whether the amount of Rs. 21 741 incurred in the purchase of types for the printing machine in the first year of its business by the assessee firm is revenue expenditure allowable as a deduction under section 10 (2) (xv) of the Incometax Act 1922 Under clause (xv) of section 10 (2) what is allowed as a deduction is any expenditure not being an allowance of the nature described in any of the clauses (i) to (xiv) inclusive and not being in the nature of capital expenditure or personal expenses of the assessee laid out or expended wholly and exclusively for the purpose of such business profession or vocation.

( 2 ) THE assessee firm is a registered firm carrying on business of publishing a daily newspaper in Gujarat called Jansatta. The business was commenced from November 4 1953 but in the very first year of its business there was a change in the personnel on August 26 1954 and therefore the accounts for that year i. e. Samvat Year 2010 (November 4 1953 to October 26 1954 were split up into two parts one from November 4 1953 to August 25 1954 and the other from August 26 1954 to October 26 1954 The assessee firm la