Sharma, J.

1. The assessee-company carries on the business of growing and manufacture of tea. During the assessment year 1973-74, relevant to the accounting period ending March 31, 1973, the assessee claimed a deduction of Rs. 33,228 paid to the Assam Electricity Board against service charges for laying service, lines, etc. The ITO disallowed the above claim. The assessee went up in appeal before the AAC, which was dismissed. The asses-see carried the matter in further appeal to the Income-tax Appellate Tribunal, Amritsar Bench. Before the Tribunal reliance was placed on a judgment of the Supreme Court in Bombay Steam Navigation Co. (1953) Private Limited v. CIT [1965] 56 ITR 52. In that case, revenue expenditure had been given the following definition (headnote):

"In considering whether expenditure is revenue expenditure, the court has to consider the nature and the ordinary course of business and the objects for which the expenditure is incurred. The question whether a particular expenditure is revenue expenditure incurred for the purpose of the business must be viewed in the larger context of business necessity or expediency. If the outgoing or expenditure is so related