The Tribunal held that the AO cannot sit in the armchair of businessman and decide whether particular expenditure is required to be incurred or not. It is also an admitted legal position that the AO cannot question rational and necessity of incurring any particular expenditure. What is required to be seen is whether particular expenditure is incurred wholly and exclusively for the purpose of business of the assessee and further such expenditure is supported by necessary evidence. In this case, the assessee has filed all possible evidence including agreement between parties to prove genuineness of expenditure incurred for supervisory services. Therefore, the AO erred in disallowing expenditure incurred by the assessee for payment made to its parent company for rendering supervisory services. The learned CIT(A), after considering relevant facts has rightly deleted additions made by the AO. Consequential to the said adjudication would be allowability of expenditure in the year of payment of TDS, which was rejected only due to conjecture by AO on deductibility of supervisory fees u/s 37. (AY. 2011-12, 2013-14, 2014-15, 2015-16)