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    <title>TEST OF ‘COMMERCIAL EXPEDIENCY’ FOR DETERMINING EXPENDITURE</title>
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    <description>The commercial expediency test requires viewing disputed expenditure from the vantage of a prudent businessman to decide deductibility. Commission payments to a sub-agent evidenced by agreements, invoices, bank transfers and TDS were contested by revenue for lack of specific service descriptions, date-wise activity records, and corroboration of interactions with the procuring authority. Documentary and corroborative proof of services rendered is necessary to establish that such payments were wholly and exclusively for business, and prior-year allowance does not relieve the assessee of the year-specific evidentiary burden.</description>
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      <description>The commercial expediency test requires viewing disputed expenditure from the vantage of a prudent businessman to decide deductibility. Commission payments to a sub-agent evidenced by agreements, invoices, bank transfers and TDS were contested by revenue for lack of specific service descriptions, date-wise activity records, and corroboration of interactions with the procuring authority. Documentary and corroborative proof of services rendered is necessary to establish that such payments were wholly and exclusively for business, and prior-year allowance does not relieve the assessee of the year-specific evidentiary burden.</description>
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