as well as the Tribunal have held that the goods in question, viz., cast iron ingot moulds are to be treated as revenue expenditure and not as capital expenditure, holding clearly that moulds do not have enduring life, which will be a parameter for considering the same as capital expenditure. The short shell life of the cast iron ingot moulds, which is to be purchased on regular basis as if it is a part of the stores of spares was treated by the Tribunal as revenue expenditure and not capital expenditure. We find no ground to take a different view from the one taken by the Tribunal, nor counsel for the Revenue is able to point out any proposition of law contrary to the above finding of the Tribunal. Since the issue revolves around pure question of fact, there is no question of law, much less substantial question of law arising for consideration in these appeals.” 3. Following the above said proposition, we are inclined to dismiss this appeal. Accordingly, this appeal is dismissed. Sd/Assistant Registrar(Judl.) Dated: 25.07.2014 //True Copy// Sub Assistant Registrar GLN To 1. The Income Tax Appellate Tribunal Madras 'A' Bench, Chennai. 2. The Commissioner of Income Tax (Appeals) Tiruchirappalli, Tiruchirapalli District,. 3. The Joint Commissioner of Income Tax Thanjavur Range, Thanjavur. + 1 cc to Mr.J.Narayanaswamy, Advocate SR.31365 T.C. (A) NO. 865 OF 2013 RSY(CO) Eu 31.07.14
