In the case of Robert Addie and Sons ' Collieries Limited vs The Commissioners of Inland Revenue(1), Lord President Clyde gave the following test: "It is necessary accordingly to attend to the true nature of the expenditure, and to ask one 's self the question, is it a part of the Company 's working expenses ? is it expenditure laid out as part of the process of profit earning ? or, on the other hand, is it a capital outlay ? is it expenditure necessary for the acquisition of property or of rights of a permanent character, the process of which is a condition of carrying on its trade at all ? The expression 'once and for all ' used in the dictum laid down in Atherton 's case (supra) was referred to by Bhagwati, J. speaking for this Court in the case of Assam Bengal Cement Co. Ltd. vs Commissioner of Income tax, West Bengal(2) and it was observed that the expression was used to denote an expenditure which is made once and for all for procuring an enduring benefit to the business as distinguished from a recurring expenditure in the nature of operational expenses.