Dismissing the appeal of the assessee the Court held that the decision taken by the subsidiary company did not bind the holding company. There was also no resolution of the holding company, deciding to send the managing director of the subsidiary company for higher studies and then take him into the fold of the holding company itself, by reason only of the education he acquired in the foreign country. The further resolution was by the assessee-company wherein the board merely agreed to reimburse the expenses. This again would be only by reason of love and affection the board members had, towards the person deputed especially noticing the fact that it was a closely held private limited company wherein all the directors were siblings or closely related. In such circumstances the expenses were not deductible.