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Whether in the facts and circumstances of thecaseand the grounds urged, the Tribunal was right or justified in holding that club membership fee of Rs. 11,29,520/- paid by appellant was in the nature of capital expenditure and therefore not deductable as revenue expenditure?

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Sec. 37 of Income Tax Act, 1961—Business Expenditure—Tribunal has to record the satisfaction that the expenditure was laid out or expended wholly and exclusively for the purpose of business of the assessee and there is no reason why the full amount should not have been allowed and in the case of assessee, no such satisfaction has been recorded by the authorities - INGERSOLL-RAND (INDIA) LTD. V/s CIT - [2020] 427 ITR 158 (KARN)