Allowing the appeal the Court held that since renovation and refurbishment of rooms, including washrooms and other facilities in hotel, only improved, efficiency of source of profit or income, expenses incurred for that purpose could not be categorized as capital expenditure but were revenue in nature. The fact that pressurisation of lift shafts resulted in ‘safety of lifts’ being enhanced, could not have led to expenses being incurred in that behalf being characterized as capital expenditure .  (AY. 1991-92, 1993-94 and 1994-95)