Dismissing the appeal of the revenue the Court held that, reasonableness of expenditure is to be judged from point of view of businessman and revenue cannot sit in arm chair of businessman to decide what is reasonable and what is not and the trustee also offered tax on remuneration received by her. Accordingly the remuneration is held to be allowable. (AY. 2005-06)
CIT v. Swadeshi Internationals (2019) 261 Taxman 430 (Karn.)(HC)
S. 37(1) : Business expenditure–Export business–Remuneration to trustees-Reasonableness of expenditure is to be judged from point of view of businessman and revenue cannot sit in arm chair of businessman to decide what is reasonable and what is not- Held to be allowable.