Expense reimbursement allowance exempt under income tax law where factual findings showed payment met employees' expenditure.

Daily allowance paid to the assessees was treated as reimbursement of expenses, not a special allowance, because the Commissioner (Appeals) and the Tribunal found as fact that it was meant to meet their expenditure and no material rebutted that finding. On that basis, the amount fell within the exemption under section 10(14) of the Income-tax Act, 1961. The contention that exemption required rendition of accounts or proof of actual expenditure was not accepted on the facts found, and no referable question of law arose.

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Issues: Whether the allowance of Rs. 150 per day received by the assessees was exempt under section 10(14) of the Income-tax Act, 1961 as a special allowance or reimbursement of expenses, and whether any referable question of law arose.

Analysis: The finding of fact recorded by the Commissioner (Appeals), and affirmed by the Tribunal, was that the amount paid per day was reimbursement of expenses and was meant to meet the assessees' expenditure. No material was produced to dislodge that finding. On that basis, the amount fell within the exemption under section 10(14). The contention that exemption depended on rendition of accounts or proof of actual expenditure was not accepted on the facts found, particularly in view of the modest daily allowance involved.

Conclusion: The allowance was held to be exempt under section 10(14) of the Income-tax Act, 1961, and no referable question of law arose.

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