( 1 ) THIS is a reference under section 25 (1) of the Expenditure Tax Act 1957 at the instance of the Commissioner of Expenditure Tax Gujarat. The assessee in this case is Shrimati Manorama Sarabhai. The assessment year with which we are concerned is the assessment year 1959-60 the accounting year being the year which ended on 31 March 1959. The assessee is a B. Sc. in Social Sciences of the London University and a graduate of the Bombay University. She devotes part of her time to running educational institutions for children. She has been associated with the Shreyas School at Ahmedabad for about fourteen years and is one of the persons running the same. The school is run in the same way as other institutions with the help of paid employees but in view of her financial position the assessee renders service to the school in an honorary capacity. At the time when she left India in or about April 1958 she applied to the Reserve Bank of India for allotment of the necessary foreign exchange. In her application she stated that she was thinking of going abroad for one year for seeing some progressive experimental schools in England and Europe that since 1947 she and her sis