https://www.taxtmi.com/caselaws?id=6467 Payments to selling agents under the 20 October 1955 agreement were treated as part of a profit-sharing arrangement, not as expenditure laid out wholly and exclusively for business under section 10(2)(xv) of the Indian Income-tax Act, 1922. The agreement gave the agents commission and interest, but also 50% of the net profits, exposure to 50% of net loss, and a controlling role in manufacturing and sales. On the facts, the substance of the arrangement was a commercial venture akin to partnership or joint venture rather than mere agency remuneration, so the sums paid out of ascertained profits were not deductible. en-us Wed, 21 Jan 1976 00:00:00 +0530 Fri, 13 Oct 2017 12:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6467 Payments to selling agents under the 20 October 1955 agreement were treated as part of a profit-sharing arrangement, not as expenditure laid out wholly and exclusively for business under section 10(2)(xv) of the Indian Income-tax Act, 1922. The agreement gave the agents commission and interest, but also 50% of the net profits, exposure to 50% of net loss, and a controlling role in manufacturing and sales. On the facts, the substance of the arrangement was a commercial venture akin to partnership or joint venture rather than mere agency remuneration, so the sums paid out of ascertained profits were not deductible. Case-Laws Income Tax Wed, 21 Jan 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6467