Rent collection commission deductible where payment enabled collection and remained within the statutory ceiling.

Special commission paid for collecting rent was claimed as a deduction under section 24(1)(viii) of the Income-tax Act, 1961. The property was assessed under section 22, and the appellate authorities found that the commission was paid to enable rent collection and was linked to the licence fees actually received, within the statutory ceiling. That concurrent factual finding supported allowance of the deduction, and no substantial question of law arose from it. The reference was therefore rightly declined.

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Issues: Whether the assessee was entitled to deduction of the special commission paid for collection of rent under section 24(1)(viii) of the Income-tax Act, 1961.

Analysis: The property was assessed under section 22 of the Income-tax Act, 1961, and the claimed expenditure was within the statutory ceiling. The appellate authorities concurrently found that the commission was paid to enable the assessee to collect rent, and the payment was linked to the licence fees actually received. That finding was one of fact, and no substantial question of law arose from it.

Conclusion: The deduction was allowable, and the reference was rightly declined.

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