Commission expenditure claimed against income from other sources...

Commission expenditure claimed against income from other sources may be deductible where evidence establishes a direct commercial nexus between the facilitation services and the commission earned. Customer purchase orders and sales records may demonstrate the payee firm's customer relationships, overlapping product trade, infrastructure and network. Where the payment is taxed in the recipient's hands and actual payment through banking channels is undisputed, such material can support admission of additional evidence and allowance of the deduction under section 57.