First-year commission deduction limited to initial year commission; renewal commission did not qualify for concessional treatment.

The Board circular granting a 50 per cent deduction was confined to first-year commission and did not extend to renewal commission received from LIC. The circular had to be read as a whole: its first paragraph expressly referred to first-year commission, and the phrase "year's commission" in the second paragraph was treated as a continuation of that reference rather than an independent grant of relief. LIC's communication to its agents could not alter the interpretation of the circular. The assessee was therefore not entitled to the concessional deduction on renewal commission, and the claim failed.

---

---

Issues: Whether the assessee was entitled to deduction at 50 per cent on renewal commission received from the Life Insurance Corporation under the Board circular.

Analysis: The circular had to be read as a whole. The first paragraph expressly referred to first-year commission, and the expression "year's commission" in the second paragraph was held to be a continuation of that reference. The reference could not be read as extending the concessional deduction to renewal commission. The LIC communication to its agents did not control the interpretation of the circular.

Conclusion: The 50 per cent deduction was confined to first-year commission and was not allowable on renewal commission. The assessee's claim failed.

---