https://www.taxtmi.com/caselaws?id=6349 Commission paid under a genuine and acted-upon selling agency arrangement was held to be deductible as business expenditure because it was laid out wholly and exclusively for business purposes. The agents were entitled to commission even on direct sales by the assessee, and their responsibilities included collection of payments and contractual performance, supporting the commercial reality of the arrangement. Prior allowance in earlier assessment years also reinforced bona fides. The Tribunal's findings were based on primary facts and factual inferences, which were not open to reappraisal in reference jurisdiction. The governing test was commercial expediency from the businessman's standpoint, and the payment was not shown to be sham or unreal. en-us Tue, 29 Aug 1972 00:00:00 +0530 Tue, 20 Jan 2026 17:10:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6349 Commission paid under a genuine and acted-upon selling agency arrangement was held to be deductible as business expenditure because it was laid out wholly and exclusively for business purposes. The agents were entitled to commission even on direct sales by the assessee, and their responsibilities included collection of payments and contractual performance, supporting the commercial reality of the arrangement. Prior allowance in earlier assessment years also reinforced bona fides. The Tribunal's findings were based on primary facts and factual inferences, which were not open to reappraisal in reference jurisdiction. The governing test was commercial expediency from the businessman's standpoint, and the payment was not shown to be sham or unreal. Case-Laws Income Tax Tue, 29 Aug 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6349