MADRAS RACE CLUB Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) AT the instance of the assessee, the following four questions were referred by the Tribunal to this court :

(2.) ON the first question, the amount disallowed was in a sum of Rs. 44,328. The Tribunal, after an elaborate discussion regarding the expenditure, found that it was not satisfied with the contention of the assessee that such expenditure was wholly and exclusively for the purpose of business. It appears that the said sum of Rs. 44,328 was spent at the time of conducting the Turf Invitation Cup. In that connection, the assessee invited members from other clubs and spent the amount on the members who had come from other clubs. The Tribunal, negativing the claim of the assessee that the expenditure was in connection with the business, held that the expenditure has no direct or indirect link with the business of the assessee. We have no valid reason to disagree with the finding of fact rendered by the Tribunal as above.