JUDGMENT - F. I. REBELLO, J. :---The question to be considered and decided in this petition is whether Conveyance Allowance paid to the members of the petitioners Association is exempted from payment of tax under section 10(14) of the Income Tax, 1961.

2.Section 10(14) of the Income Tax Act, 1961 reads as under :--

(14)(i) any such special allowance or benefit, not in the nature of a perquisite within the meaning of Clause (2) of section 17, specifically granted to meet expenses wholly, necessarily and exclusively incurred in the performance of the duties of an office or employment of profit, (as may be prescribed), to the extent to which such expenses are actually incurred for that purpose ;

(ii) any such allowance granted to the assesses either to meet his personal expenses at the place where the duties of his office or employment of profit are ordinarily performed by him or at the place where he ordinarily resides, or to compensate him for the increased cost of living, (as may be prescribed and to the extent as may be prescribed).

(Provided that nothing in sub-clause (ii) shall apply to any allowance in the nature of personal allowance granted to the assessee to remunerate or com

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