O. P. JAIN, J.M.: Revenue is in appeal against order dt. 7th Aug., 1984 passed by AAC "N" range, New Delhi relating to asst. yr. 1980-81 whereby addition of Rs. 24,000 was deleted. In year 1976, assessee was allotted shed in New Okhla-I Industrial Complex by Delhi Small Industries Development Corporation Ltd. (DSIDC for short) on monthly rent. During year under consideration no rent of said shed was paid by assessee but in revised return of income she claimed deduction of Rs. 24,000 being rent of said shed as payable to DSIDC. AO disallowed claim with observation that dispute is going on and assessee is claiming that payment is to be adjusted towards price of shed and not as rent. He also observed that even payments made for earlier years are being claimed by assessee as payment towards price of shed. assessee went up in appeal before AAC, who accepted assessee s claim. Aggrieved by that order Revenue is in appeal before us. We have heard both sides on point. It has been argued on behalf of Department that no rent was actually paid by assessee, and on account of assurance issued by Lt. Governor of Delhi, assessee is to get s h e d in question on hire purchase basis and amount claimed by assessee tantamount to payment towards price of shed. On other hands, authorised representative for assessee has admitted that though such assurance was issued by Lt. Governor of Delhi but nothing has materialised as yet and no hire purchase scheme has come into being. He has invited our attention to Paper No. 1 of paper book, which is letter of allotment by DSIDC. It suggests that shed in question was allotted to assessee on rental basis. Papers Nos. 2 to 13 of assessee s paper book is copy of lease deed, which also suggests that assessee had acquired shed on rental basis. Paper Nos. 14 to 18 of paper book also go to indicate that DSIDC is claiming rent from assessee. However, Paper No. 20 of paper book is copy of written assurance issued by Lt. Governor of Delhi in March, 1977. It speaks that DSIDC sheds in Delhi will be sold to entrepreneurs on hire purchase basis as already announced by Chief Executive Councillor. It also mentions that price and mode of payment will be determined later on by body to be appointed. It appears that to said assurance assessee is claiming that shed in question should be transferred to her on hire purchase basis and payments already made by her should be adjusted towards price of shed. There is nothing on record to suggest whether anything concrete has come into existence after said assurance has been issued by Lt. Governor of Delhi. In case shed is to be transferred to assessee under any hire purchase scheme, then payment made towards such scheme would be towards price of shed and such payment cannot amount to revenue expenditure. In case payment is made as rent, then same is allowable as revenue expenditure. It is not in dispute that assessee is following mercantile system of accounting. In case of payments of rent, she is entitled to claim deduction even if no rent has been actually paid by her. However, we feel that sufficient material is not available on record on basis of which it can be ascertained whether amount claimed by assessee should be treated as rent or towards payment of price of shed. In our opinion, further enquiry is needed to arrive at correct conclusion. We, therefore, set aside order of AAC and restore appeal to his file for fresh decision. It will be open to parties to adduce further evidence on point. For statistical purposes, appeal shall be treated as followed. *** INCOME TAX OFFICER v. SMT. HANSA BAHADUR