Held, that the assessee had paid sponsorship fees in terms of an agreement to carry out business promotional activities. Under the terms of the agreement, the trust was to carry out various sponsorship activities in the assessee’s name as sponsor against yearly payment of Rs. 2.50 crores. The payment was backed by the agreement and invoices and the Department had no material to doubt these. The assessee had also furnished the details of actual expenditure incurred on business promotional activities. In such a case, it was not open for the Assessing Officer to question the commercial wisdom of the assessee as to how the business was to be promoted. The assessee’s logo had been used on stationery items and other record books which would be used by a large number of students which enhance the image of the assessee in the minds of the parents of the students. Similarly, there was no basis to arrive at a conclusion that 50 per cent. of other expenditure was to be considered as an expenditure qualifying the test laid down under section 37(1).(AY.2013-14, 2014-15)