Binding precedent governed Rule 6D travel expense and investment allowance issues, both resolved for the assessee.

Disallowable expenditure under Rule 6D had to be computed with reference to individual tours, because the issue was covered by binding precedent; the question was therefore answered in favour of the assessee and against the Revenue. Investment allowance under section 32A was available on the value of plant and machinery leased by the assessee, because that issue was also covered by binding Supreme Court precedent; the question was likewise answered in favour of the assessee and against the Revenue. The Court reiterated that a referred question governed by binding precedent must be answered in accordance with that precedent.

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Issues: (i) Whether disallowable expenditure under Rule 6D was to be computed by taking into account all tours made by a particular employee during the entire previous year or on the basis of individual tours; (ii) Whether the assessee was entitled to investment allowance under section 32A on the value of plant and machinery leased by it.

Issue (i): Whether disallowable expenditure under Rule 6D was to be computed by taking into account all tours made by a particular employee during the entire previous year or on the basis of individual tours.

Analysis: The issue was stated to be covered by binding precedent of the Court, and the parties accepted that position.

Conclusion: The question was answered in the affirmative, in favour of the assessee and against the Revenue.

Issue (ii): Whether the assessee was entitled to investment allowance under section 32A on the value of plant and machinery leased by it.

Analysis: The issue was stated to be squarely covered by binding precedent of the Supreme Court, and the parties accepted that position.

Conclusion: The question was answered in the affirmative, in favour of the assessee and against the Revenue.

Final Conclusion: Both referred questions were answered in favour of the assessee, and against the Revenue.

Ratio Decidendi: Where a referred question is covered by binding precedent, it is answered in accordance with that precedent.

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