The assessee constructed a building on leasehold land which, under the lease agreement, had to be handed back to the lessor upon expiry of the lease. Following its earlier decision in the assessee’s own case, the Tribunal held that the assessee did not acquire ownership of the capital asset and the expenditure incurred on construction was allowable as revenue expenditure. The order of the Commissioner (Appeals) allowing the claim was upheld.  Dealy of 59 days and 206 days was condoned. (AY. 2017-18, 2018-19 & 2020-21).