https://www.taxtmi.com/caselaws?id=327136 Concurrent factual findings that commission was genuinely paid for promotion of export sales and was directly linked to business activity supported allowance as revenue expenditure under section 37(1), and no substantial question of law arose because the findings were not shown to be perverse. Payment to a foreign agent was treated as covered against the Revenue by binding precedent, so the alleged characterisation as fees for technical services under section 9(1)(vii) and the related disallowance under section 40(a)(i) did not survive. The article emphasises that, in section 260A appeals, concurrent findings on genuineness and business purpose will not be interfered with absent perversity. en-us Tue, 26 Apr 2016 00:00:00 +0530 Tue, 03 May 2016 17:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=327136 Concurrent factual findings that commission was genuinely paid for promotion of export sales and was directly linked to business activity supported allowance as revenue expenditure under section 37(1), and no substantial question of law arose because the findings were not shown to be perverse. Payment to a foreign agent was treated as covered against the Revenue by binding precedent, so the alleged characterisation as fees for technical services under section 9(1)(vii) and the related disallowance under section 40(a)(i) did not survive. The article emphasises that, in section 260A appeals, concurrent findings on genuineness and business purpose will not be interfered with absent perversity. Case-Laws Income Tax Tue, 26 Apr 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=327136