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    <title>2013 (10) TMI 839 - GUJARAT HIGH COURT</title>
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    <description>Commission paid for transferring a contractual obligation linked to import of furnace oil was held not deductible under section 37(1) because the underlying transaction was prohibited by the applicable licence regime and the Explanation to section 37(1). The court treated the payment as consideration for a legally barred purpose, and rejected reliance on its description as commission or on the absence of revenue loss. Business promotion expenditure for sending mangoes was also disallowed on facts, as there was no material showing business expediency or necessity, and the court found no substantial question of law warranting interference.</description>
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      <description>Commission paid for transferring a contractual obligation linked to import of furnace oil was held not deductible under section 37(1) because the underlying transaction was prohibited by the applicable licence regime and the Explanation to section 37(1). The court treated the payment as consideration for a legally barred purpose, and rejected reliance on its description as commission or on the absence of revenue loss. Business promotion expenditure for sending mangoes was also disallowed on facts, as there was no material showing business expediency or necessity, and the court found no substantial question of law warranting interference.</description>
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