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In judging the capital or revenue character of expenditure on tools or machinery spares the Tribunal in [2022] 27 ITR (Trib)-OL 241 (ITAT[Bang]) held that the test of enduring benefit is not the only criteria for concluding an item to be revenue or capital in nature. The bench on their look to the list of machinery spares found that they do not function as independent machines. The often referred pet decision of SC in Saravana Spinning Mills did not even help revenue in this case. 

In this case the AO held that the items of spares /tools have a life beyond 12 months hence they are to be treated as capital in nature.

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