Dismissing the appeal of the assessee the Court held that ; there could be no deduction permissible on the cost of acquisition without generation of income credited in the books of account. The films in question were never commercially exploited and generated no income. The assessee was required to credit the amount realised by it by exhibiting the film in the profit and loss account. The feature films were never exhibited and there was no amount credited in the profit and loss account as amount received on exhibition of films. The finding of the  Appellate Tribunal is up held .