Rule 6D expense ceiling applies to a partner's hotel es, as "any other person" includes partners.

Rule 6D of the Income-tax Rules, 1962 was construed broadly to cover hotel expenses incurred by a partner of a firm. The Delhi High Court held that the phrase "an employee or any other person" did not exclude a partner, so the ceiling under rule 6D applied to such expenses incurred in the course of the firm's business. On that construction, the disallowance of the hotel expenses was sustained, and the issue was answered in favour of the Revenue and against the assessee.

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Issues: Whether hotel expenses incurred by a partner of the assessee-firm were subject to the ceiling prescribed by rule 6D of the Income-tax Rules, 1962, and whether the expression "an employee or any other person" excluded a partner.

Analysis: The expression "an employee or any other person" was construed broadly. The Court held that there was no reason to restrict the phrase so as to exclude a partner of the firm. The ceiling under rule 6D therefore applied to expenses incurred by a partner in the course of the firm's business. The wider construction adopted by another High Court in relation to directors was treated as supporting authority for the same approach.

Conclusion: A partner is included within the expression "any other person" in rule 6D, and the disallowance of the hotel expenses was sustained; the question was answered in favour of the Revenue and against the assessee.

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