Foreign tour expenditure deduction denied where business benefit was only incidental, not the sole purpose of travel.

Foreign tour expenditure was deductible only if incurred wholly and exclusively for the assessee's business, profession or vocation under section 10(2)(xv) of the Indian Income-tax Act, 1922. The court applied the statutory test that the sole purpose of the outlay must be business-related, and held that the assessee's primary object in going abroad was to attend a congress. Any lecture activity or incidental benefit to his magazine or professional standing was merely remote and secondary. The tribunal had applied the wrong standard by asking whether the expense had nothing to do with the profession. The expenditure was therefore not allowable as a deduction.

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Issues: Whether the foreign tour expenditure was laid out wholly and exclusively for the purpose of the assessee's business, profession or vocation under section 10(2)(xv) of the Indian Income-tax Act, 1922.

Analysis: The statutory condition required the expenditure to be incurred for the sole purpose of advancing the assessee's business, profession or vocation. The assessee's primary object in going abroad was to attend the congress, and any lecture activity or possible benefit to his magazine or professional standing was only incidental. The tribunal had applied the wrong test by asking whether the expenditure had nothing to do with the profession, instead of whether it was incurred wholly and exclusively for that purpose. On the admitted facts, the professional advantage, if any, was only remote and secondary.

Conclusion: The expenditure was not incurred wholly and exclusively for the purpose of the assessee's business, profession or vocation and was therefore not allowable under section 10(2)(xv).

Ratio Decidendi: For deduction under section 10(2)(xv), the expenditure must be incurred for the sole purpose of the business, profession or vocation, and incidental or remote professional benefit is insufficient.

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