The question whether a particular expenditure is a capital expenditureor a revenue expenditure has to be decided on the basis of the facts and circumstances of each case.
The phrase "capital expenditure" has not been defined in the Act and sound accountancy principles also have to be kept in view for deciding this controversy. Some tests have been laid down in cases but ultimately the answer will depend upon the facts and circumstances of each case.
See the Commissioner of Income Tax vs Warrier Hindustan Ltd, (1986) 160 ITR 217, 236 (AP). The controversy will continue as there can be no finality on the issue.