JUDGMENT

By this petition under section 256(2) of the Income Tax Act, 1961 (for short "the Act"), the Revenue seeks a direction to the Incometax Appellate Tribunal to state the case and refer the following questions, in respect of the assessment year 198586, for the opinion of this Court:"(1) On the facts and in the circumstances of the case and in law whether the Tribunal was correct in holding that the expenses of Rs.31,56,117 spent by the assessee on repairs and replacements of central air conditioning plant were of Revenue nature?(2) On the facts andthe circumstances of the case and in law whether the Tribunal was correct in holding that a deduction of Rs.9,07,358 was allowable to the assessee under section 32A(2)(b)(iii) on fire­ fighting equipments?"During the course of the assessment proceedings, the Assessing Officer noticed that the assesseecompany had claimed Rs.31,56,117 as repairs and replacement of central airconditioning plant and insulated chilled water piping rerouting. Reje...