( 1 ) M/s Bhanna Mal and Company Private Ltd. , Delhi, the assessee, during the assessment year 1956-57 (for which the accounting year ended on October 25, 1955), spent a sum of Rs. 130. 00 in its Patna branch and Rs. 65. 00 in its Alwar branch over the salary of a pujari. who used to invoke the blessings of Gods and Goddesses of prosperity for the benefit of assessec. The Incometax Officer disallowed both these items as not being a deductable expense without assigning any reason. The assessee appealed. The Appellate Assistant Commissioner confirmed the dis-allowance observing that the assessee had failed to prove as to how these expenses we necessary for the purpose of running the business.

( 2 ) ON Second appeal, the income-tax Appellate Tribunal held that although such expenses might not be tangibly connected with the carrying on of the business, it had certainly an intangible bearing on it since to a God fearing man such expenses were expense which create a sense of security and prosperity and add to assessece s general capability to do better busines. Accordingly, the assessee s claim to deduct the said items as an admissible expenses was allowed On an applicati