ORDER : Akil Kureshi, J. The Revenue's tax appeal has been admitted for consideration of the following substantial question of law: “Whether the Appellate Tribunal is right in law and on facts in confirming the order passed by the CIT (A) directing to allow the expenditure claimed by the assessee against the disallowance of Rs. 1,35,86,571/- in respect of deferred revenue expenditure, though not debited to the profit and loss account?” 2. Briefly stated, the facts are as under. The respondent assessee is a company registered under the Companies Act and is engaged in the business of manufacturing Air conditioner. For the assessment year 1996-1997, the assessee's return was taken in scrutiny by the Assessing Officer. One of the issues which came up during such scrutiny assessment was with respect to various expenditures incurred by the assessee during the accounting period relevant to the assessment year in question. Such expenditures pertained to information and technology, sales promotion, purchase of software and market research expenses. Total of such expenditures came to Rs. 1.67 crores (rounded off). The assessee however, debited only a portion thereof of Rs. 32.10 crores (rounded off) in the profit and loss account for the said year and deferred debiting such expenditure to the subsequent years. In the return, however, the assessee had claimed entire expenditure of Rs. 1.67 crores by way of deduction under section 37 of the Income Tax Act, 1961 (“the Act” for short). The Assessing Officer disputed such claim. The assessee contended that the expenditure was incurred during the year under consideration. The same was in the nature of revenue expenditure and, therefore, allowable under section 37 of the Act. The Assessing Officer however, rejected such a claim barring Rs. 32.10 lacs which was debited by the assessee in profit and loss accounts. He was of the opinion that the accounting treatment given by the assessee to such expenditure in the books of account was accurate. It was not in conflict with any specific provision of the statute. In that view of the matter, claim of the assessee which was in conflict with its own accounting treatment given to the expenditure, was not allowable. 3. CIT(Appeals) allowed the appeal of the assessee and reversed the decision of Assessing Officer on the issue upon which the Revenue filed appeal before the Tribunal. In that view of the matter, claim of the assessee which was in conflict with its own accounting treatment given to the expenditure, was not allowable. 3. CIT(Appeals) allowed the appeal of the assessee and reversed the decision of Assessing Officer on the issue upon which the Revenue filed appeal before the Tribunal. The Tribunal noted that the prime reason for the Assessing Officer to disallow the claim was the accounting treatment that the assessee had given to such expenditure. The same being in consonance with the accounting principles and the method of accounting rightly employed by the assessee, the claim of expenditure contrary to such accounting entires was not valid. The Tribunal in this respect recorded that it was not the case of the Revenue that expenditure was in the nature of capital expenditure. Thus being an expenditure in the nature of revenue expenditure, was allowable during the year of expenditure and accounting entries would not be decisive of the nature of treatment that this expenditure should receive. The Tribunal also recorded that expenditure not being in the nature of capital expenditure, the same would be treated as Revenue expenditure and cannot be disallowed on the ground that the same would give an enduring benefit to the assessee. Reference was made to the decision of the Supreme Court in case of Kedarnath Jute Mfg. Co. Ltd. v. Commissioner of Income-tax (central) Calcutta reported in (1971) 82 ITR 363 (SC) to hold that mere accounting entries would not be conclusive of the nature of expenditure. 4. It is against this judgement of the Tribunal that the Revenue has filed this appeal. 5. We notice, as correctly pointed out by the parties, that the issue is squarely covered by the decision of Supreme Court in case of Taparia Tools Ltd. v. Joint Commissioner of Income-tax reported in (2015) 372 ITR 605 (SC). In the said decision, the assessee had issued non convertible debentures in which option was given to the subscribers to receive interest periodically over a period of debenture or one time lump-sum payment of lower amount payable immediately. The one time payment of interest was however, shown by the assessee in the books as deferred expenditure to be written off over the entire period of debentures. The assessee however, claimed the entire expenditure under section 36(1)(iii) of the Act during the year under consideration upon which the Revenue objected. The one time payment of interest was however, shown by the assessee in the books as deferred expenditure to be written off over the entire period of debentures. The assessee however, claimed the entire expenditure under section 36(1)(iii) of the Act during the year under consideration upon which the Revenue objected. The Supreme Court held that under section 36(1)(iii) of the Act any amount paid on account of interest becomes an admissible deduction if the same was paid on the capital borrowed by the assessee and the borrowing was for the purpose of business or profession. While examining ‘the allowability of such deduction, the Assessing Officer is to consider the genuineness of the business borrowing and that the borrowing was for the purpose of business and not an illusionary and colourable transaction. It was further held that the amount would be said to have been paid even if same is not actually paid but incurred on the sis of method of accounting. It was further held and observed that there is no concept of deferred revenue expenditure in the Act except under certain specified sections where amortisation is specifically provided. Normally, the ordinary rule would be that the revenue expenditure incurred in a particular year is to be allowed in that year. If the assessee claims the expenditure in the year when the same was made, the department cannot deny it. The decision of Supreme Court in case of Madras Industrial Investment Corporation Ltd. v. CITreported in (1997) 225 ITR 802 (SC), where the assessee had claimed spread over of the expenditure which was allowed was noticed and explained. 6. In view of the decision of Supreme Court in case of Taparia Tools Ltd.(supra), the question is answered against the Revenue. 7. Tax appeal is dismissed.