A.L. Gehlot, A. M.: This appeal is filed by Revenue against order of CIT(A)-V, Ahmedabad, dt. 9th Nov., 1998 for asst. yr. 1994-95. first ground raised by Revenue in its appeal is pertaining to deletion of disallowance of electric bill of residence of director. disallowance made by AO has been deleted by CIT(A) with observation that perquisite value of free supply of electricity to residence of director has been shown by him in his return of income. We have heard learned Representatives of parties and perused record. After considering facts and above observation of CIT(A), we are of view that when perquisite value of free supply of electricity has already considered in hands of director, therefore, disallowance in case of company i.e. employer is not justifiable. We find that CIT(A) has correctly deleted impugned addition of Rs. 64,588. second ground raised in this appeal is pertaining to deletion of disallowance of foreign travelling expenses. During assessment proceedings, AO noticed that assessee claimed expenditure on foreign travelling at Rs. 3,46,403. AO noticed that Smt. Rajniben Chokshi, director of assessee company, has undertaken visits to Switzerland, USA and has incurred expenditure of Rs. 1,22,096. AO noticed that Smt. Rajniben Chokshi is non-working director of assessee company and is housewife and was neither looking business operation of assessee company nor was qualified to look after such specialised trade as manufacturing and export of chemicals. AO noticed that there was no evidence that Smt. Rajniben Choksi has actually rendered any services to assessee company during her overseas visit. AO noticed that Smt. Rajniben Choksi is wife of Shri Navnitbhai Chokshi, managing director of assessee company. AO relied upon judgment of jurisdictional High Court in case of CIT vs. Shaibaug Entrepreneurs (P) Ltd. 1995 Tax LR 133, wherein it has been held that if assessee has failed to lead any evidence to show as to how foreign visit was necessary in order to facilitate negotiations at top level with foreign corporations expenditure incurred cannot said to be for purpose of business. AO further noticed that foreign visit was from 11th June, 1993 to 14th July, 1993. On scrutiny of report of sister-concern of assessee, M/s Engee Chemicals Industries (P). Ltd. has also claimed foreign travel expenses which were incurred by husband of Smt. Rajniben Chokshi in that period. AO concluded that material available on record proves that both have made pleasure trip to USA and Switzerland. He, accordingly, disallowed Rs. 1,22,096 by holding that same is not incurred wholly and exclusively for purpose of business of assessee. CIT(A) deleted addition. learned Authorised Representative submitted that Smt. Rajniben Chokshi is holding M.A. Degree and she is director of assessee company since incorporation of company in 1978. He further submitted that she is fully conversant with business activities of assessee company. learned Authorised Representative further submitted that due to foreign visit assessee company received business from M/s Trade Search Assoc. and others of which details have been given by CIT(A) at p. 9 of his order. Authorised Representative further submitted that during her visit to Singapore, she met three parties but no orders have been received from parties. learned Authorised Representative made alternate arguments and submitted that if visit of director is taken as pleasure visit even then no expenses are disallowable in view of judgment of jurisdictional High Court in case of Sayaji Iron & Engg. Co. vs. CIT (2002) 172 CTR (Guj) 339: (2002) 253 ITR 749 (Guj). learned Departmental Representative, on other hand, relied upon order of AO and submitted that claim of allowability of foreign travelling expenses is of assessee and if assessee failed to support its claim by evidence and material, such claim is not allowable. learned Departmental Representative in support of his contention relied upon judgment of apex Court in case of CIT vs. Calcutta Agency Ltd. (1951) 19 ITR 191 (SC). We have heard learned Representatives of parties and perused record. We find that assessee has failed to support claim of expenses on account of foreign travel expenses incurred by Smt. Rajniben Chokshi, director of assessee company. We find that assessee has also failed to prove that said expenditures were actually incurred for purpose of business or Smt. Rajniben Chokshi has rendered any services to assessee company during her overseas visit which can be said to be for purpose of business o f assessee company. AO has specifically asked assessee to furnish necessary evidence in support of claim. AO observed that assessee in its written reply before AO merely gave names of parties to whom Smt. Rajniben Chokshi has made contact during her overseas visit. Any expenditure not being in nature of capital expenditure or personal expenses laid out or expended wholly or exclusively for purpose of business is allowable expenses under IT Act. It is necessary in order to determine controversy under consideration to consider what constitutes business of assessee. We must consider what are activities which constitute such business. There are various activities combined together constituted business; merely pointing out some names of traders or businessmen does not constitute for purpose of business. status of assessee is company and its activities are regularised by Companies Act. All important business activities particularly where substantial money is involved, necessary resolution of board and minutes, etc. are to be required to be recorded. Even while presenting annual report by board of directors along with financial statements such important activities are required to be discussed and its achievements and failures are also required to be put on record. We find that assessee has failed to submit any such record before lower authorities or before us. After having carefully gone through orders of lower authorities, we find that assessee has completely failed to give any evidence to show that foreign visit was necessary for purpose of assessee s business. alternate submission of learned Authorised Representative that matter is covered by jurisdictional High Court decision in case of Sayaji Iron & Engg. Co. (supra) is not acceptable in fact and law. facts of that case and facts of case under consideration are entirely different and distinguishable. If we accept alternate contention of learned Authorised Representative then AO is not empowered to disallow any non-business expenses in case of company, we find that such proposition has not been laid down by jurisdictional High Court in case cited by learned Authorised Representative. Contrary we find substance in submission of learned Departmental Representative that assessee has made claim for allowing foreign visit expenses, onus is on assessee, in view of judgment cited by him. We find that assessee has failed to discharge its onus. Under circumstances, we find that CIT(A) has wrongly deleted t h e impugned addition. Under circumstances and in light of above discussion, we set aside order of CIT(A) and restore that of AO and accordingly confirm addition of Rs. 1,22,096. In result, appeal of Revenue is partly allowed. *** JOINT COMMISSIONER OF INCOME TAX v. ANAR CHEMICALS (P) LTD.