JUDGMENT : R.C. Mankad, J. The Income-tax Appellate Tribunal ("the Tribunal" for short) has referred to us, for our opinion, the following question, under section 256(1) of the Income-tax Act, 1961 ("the Act" for short) : "Whether, on the facts and in the circumstances of the case, the expenditure of Rs. 32,382 being 'Guest house expenses' are trading expenses and not dis-allowable under section 37(4) of the Income-tax Act, 1961 ?" 2. The assessee is a private limited company carrying on the business of providing facilities to staff members of various sister concerns. The facilities which are provided by the assessee include lodging and boarding. It had taken premises on rent for providing these facilities and incurred a total expenditure of Rs. 32,382 for payment of rent to the landlords from whom premises were taken on rent for running the aforesaid business. The said expenditure was incurred under the heading "Guest house expenses". The Income-tax Officer held that since the expenditure which the assessee had incurred was for maintenance of guest house, deduction thereof could not be allowed under section 37(4)(i) of the Act. On appeal, however, the Appellate Assistant Commissioner held that the expenditure which the assessee had incurred was trading expenditure which was allowable as deduction while computing profits under section 28 of the Act. Therefore, according to the Appellate Assistant Commissioner, the question of disallowing the said expenditure under section 37(4) of the Act need not arise. He, therefore, allowed the assessee's claim for deduction of the aforesaid expenditure. On further appeal, the Tribunal confirmed the view taken by the Appellate Assistant Commissioner. It is in the background of the above facts that the question stated above has been referred to us for our opinion. 3. There is a concurrent finding of fact by the Appellate Assistant Commissioner and the Tribunal that the expenditure of Rs. 32,382 which the assessee has incurred is trading expenditure, deduction whereof is permissible under section 28 of the Act. Having regard to the facts and circumstances of the case, this view taken by the Tribunal and the Appellate Assistant Commissioner is correct. The business of the assessee is to provide facilities to staff members of other companies. 32,382 which the assessee has incurred is trading expenditure, deduction whereof is permissible under section 28 of the Act. Having regard to the facts and circumstances of the case, this view taken by the Tribunal and the Appellate Assistant Commissioner is correct. The business of the assessee is to provide facilities to staff members of other companies. As pointed out above, the facilities which the assessee provided include lodging and boarding facilities to the said staff members and it is to provide these facilities that the assessee has taken premises on rent. The expenditure in question was incurred for payment of rent. Since it is the business of the assessee to provide facilities as stated above and it was for the said business it had rented premises and paid rent of Rs. 32,382, it is obvious that the expenditure of Rs. 32,382 is a trading expenditure, deduction whereof is permissible under section 28 of the Act. We, therefore, uphold the view taken by the Tribunal and answer the question which has been referred to us, in the affirmative and against the Revenue. Reference answered accordingly with no order as to costs.