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Issues: Whether remuneration received by a director of a private limited company constitutes salary so as to entitle the director to standard deduction under section 16(i) of the Income-tax Act, 1961.
Analysis: The governing principle applied was that a director of a company is not, merely by reason of holding that office and receiving remuneration, in an employer-employee relationship with the company. On that basis, remuneration paid to a director cannot automatically be treated as salary for the purpose of claiming deduction under section 16 of the Income-tax Act, 1961.
Conclusion: The remuneration received by the director was not salary and no deduction under section 16(i) of the Income-tax Act, 1961 was allowable.