( 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 sister-in-law had founded a school named Shreyas which had been recognised by the Bombay State as an experimental school and that her idea in going abroad was two-fold. One of her ideas was that she wanted to study educational psychology which she felt would help her in the understanding of children and that she had written to the Tavistock Institute to let her have the benefit of their course in educational psychology and that the Institute had agreed to do so. She also wanted to see the working of schools both in England and Europe whenever time permitted her to do so. She further stated that if given the requisite exchange she would be going with ten years experience in a school and felt that it would help her to imbibe what was best abroad and bring it out to be incorporated in the education imparted in India. She secured admission in the Tavistock Clinic of Mental Hygiene London for the purpose of training in education and clinical psychology She completed the training in June 1959 and was accepted for a further year as an associate student in the adult department of the clinic for the year 1959-60 also. She traveled to places like Switzerland Holland and Scandinavia for the purpose of studying institutions connected with children in those countries. In the aforesaid activities she incurred expenses to the extent of Rs. 13 952 during the year ending on 31st March 1959. She claimed that she was entitled to an exemption in respect of the expenditure incurred as aforesaid under section 5 (a) of the Expenditure Tax Act 1957 She succeeded in her contention before the Income Tax Appellate Tribunal. Thereupon at the instance of the Commissioner of Expenditure Tax this reference has been made for the purpose of determining the question following :-WHETHER on a true interpretation of sec. 5 (a) of the Expenditure Tax Act 1957 the educational activities of the Respondent amount to business profession vocation or occupation.

( 2 ) SECTION 5 (a) of the Expenditure Tax Act 1957 runs as follows :-5. No expenditure-tax shall be payable under this Act in respect of any such expenditure as is referred to in the following clauses and such expenditure shall not be included in the taxable expenditure of an assessee (a) any expenditure whether in the nature of revenue expenditure or capital expenditure incurred by the assessee wholly and exclusively for the purpose of the business profession vocation or occupation carried on by hire or for the purpose of earning income from any other source;.

( 3 ) THE learned Advocate General who appears on behalf of the Commissioner urged that the words business profession vocation or occupation as used in this section should be understood in the same sense in which the words business profession or vocation have been used under the I