Business expenditure for foreign technical tour accepted where director attended a congress to improve sugar production methods.

Expenditure on a director's foreign tour to attend an international sugarcane technologists' congress was treated as business expenditure because it was closely connected with the assessee's sugar-manufacturing business and aimed at acquiring the latest production techniques. The Tribunal's finding on that business nexus was treated as final. A further objection that the amount related to a different assessment year was not entertained because it had not been raised or decided as a question of law before the Tribunal, and could not be introduced for the first time in reference proceedings. The expenditure was therefore allowable, and the issue was answered in favour of the assessee.

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Issues: Whether the expenditure incurred on the foreign tour of a director for attending an international sugarcane technologists' congress was allowable as business expenditure, and whether the department could dispute the allowance on the ground that the expenditure related to a different assessment year.

Analysis: The director's tour was accepted as closely connected with the assessee's business of sugar manufacture, since it was undertaken to acquire the latest techniques of sugar production. The Tribunal's finding on this aspect was treated as final. The additional contention that the amount related to a different assessment year had not been raised or decided before the Tribunal as a question of law arising from its order, and could not be newly agitated in the reference proceedings.

Conclusion: The expenditure was held to be allowable as business expenditure, and the question was answered in the affirmative, against the revenue.

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