first ground in this appeal is against disallowance of expenditure of Rs. 52,982 in respect of planting of trees in avenues in industrial estate. ITO disallowed same as capital expenditure which was upheld on appeal by Commissioner (Appeals). learned counsel for assessee submitted that expenditure incurred did not result in creation of any asset and it did not derive and benefit of enduring nature. Hence, it should be allowed as revenue expenditure. learned departmental representative justified disallowance. 2. We have considered rival submissions. In our view, by incurring expenditure of Rs. 52,982 on planting of trees in avenues in industrial estate, no income-yielding asset has been created nor any benefit of enduring nature has been derived. By planting trees, as better atmosphere and look is given to industrial estate. But, thereby, it cannot be held that enduring benefit has been derived by assessee. Even test of enduring benefit is not certain or conclusive test as held by Supreme Court in Empire Jute Co. Ltd. v. CIT [1980] 124 ITR 1. Supreme Court pointed out that even if expenditure is incurred for obtaining advantage of enduring benefit, there may be cases where expenditure may nonetheless be on revenue account and test of enduring benefit may break down. What is material to consider is nature of advantage in commercial sense and it is only where advantage is in capital field that expenditure would be disallowable on application of this test. above ratio squarely applies to instant case. No income-yielding capital asset has been created by planting trees and no enduring benefit has been derived by assessee. Thus, expenditure incurred is allowable as revenue expenditure. Accordingly, we allow same and delete addition of Rs. 52,982. 3. Ground No. 2 relating to expenditure on land survey is not pressed. Accordingly, it is dismissed. 4. In result, appeal is partly allowed. *** A.P. INDUSTRIAL INFRASTRUCTURE CORPORATION LTD. v. INCOME TAX OFFICER