Special allowance exemption applies to reimbursements for duty-related expenses, including any surplus over actual spending.

An amount granted to meet the expenses of managing and running a retail cloth shop was treated as exempt as a special allowance, benefit or perquisite under section 4(3)(vi) of the Indian Income-tax Act, 1922. The decisive test was whether the payment was made for expenses wholly and necessarily incurred in performing the duties, not whether the recipient actually spent the whole sum or matched expenditure exactly. Where the factual finding was that the amount was received to reimburse advertisement and other business expenses, the exemption applied to the entire receipt, including any surplus over actual expenditure.

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Issues: Whether the amount received for meeting the expenses of managing and running the retail cloth shop was exempt under section 4(3)(vi) of the Indian Income-tax Act, 1922, including the surplus over actual expenditure.

Analysis: The provision exempts a special allowance, benefit or perquisite specifically granted to meet expenses wholly and necessarily incurred in the performance of duties. The decisive factor is whether the amount was granted for that purpose, not whether the assessee actually spent the whole amount or whether the grant exactly matched the expenditure. The Tribunal's finding that the amount was received for reimbursing advertisement and other expenses was binding, and the section did not require proof that the whole sum was actually expended.

Conclusion: The entire amount received, including the surplus over actual expenditure, was exempt under section 4(3)(vi).

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