Judgment :- Radhakrishnan, J. Assessee is the appellant. This is an appeal filed under section 260A of the Income Tax Act, 1961 aggrieved by the order of the Income-tax Appellate Tribunal, Cochin Bench in ITA.No.826(Coch)/1995 Following is the question of law raised: Whether on the facts and circumstances of the case was the Tribunal justified in holding that the amount of Rs.45,000/- paid by the assessee for taking institutional membership in the Cochin Yacht Club is a capital expenditure not allowable as business expenditure under the Income-tax Act? Assessee is engaged in the manufacture of multipin connectors. Assessee has stated that it had paid an amount of Rs.45,000/- to Cochin Yacht Club towards institutional membership fee. Assessing officer disallowed the claim of Rs.45,971/- being payment effected by the assessee to club on the ground that it was not connected with the business of the assessee. However, on appeal, commissioner (Appeals) allowed the assessee’s claim. Aggrieved by the same revenue took up the matter before the Tribunal. Tribunal however took the view that the expenditure incurred by the assessee for taking membership in the club is capital expenditure and consequently the order passed by the commissioner was reversed and confirmed the disallowance made by the assessing officer. Aggrieved by the same this appeal has been preferred. 2. We are in agreement with the view of the Tribunal that the expenditure effected by the assessee is capital in nature. Once the assessee pays the amount to a club for membership, it is a payment once and for all resulting in an enduring benefit to the institution. The mere fact that the assessee’s representative, like the Managing Director’s participation in the club promotes the assessee’s business does not change the character of the payment which was made once and for all. The apex court in Punjab State Industrial Development Corporation Ltd. v. CIT (225 ITR 792) held that when an expenditure is made not only once and for all, but with a view to bringing into existence an asset or an advantage for the enduring benefit of a trade, there is a very good reason (in the absence of special circumstances leading to an opposite conclusion) for treating such an expenditure as properly attributable not to revenue but to capital”. 3. 3. We are of the view that the above principle would squarely apply in a case where the company has made an expenditure for getting institutional membership in a club and it is an expenditure as properly attributable not to revenue but to capital. We therefore answer the question in favour of the revenue and against the assessee. Consequently this appeal is dismissed.