https://www.taxtmi.com/caselaws?id=276294 Deductibility of remuneration to a technical adviser under section 10(2)(xv) of the Income-tax Act, 1922 depended on whether the expenditure was laid out wholly and exclusively for business purposes. The assessee bore the burden of proving commercial expediency, and reasonableness could not rest on its own assertion alone; revenue authorities were entitled to examine surrounding circumstances. On the facts, the adviser's appointment and payment were influenced by factors such as prior relationships, shareholding position, unclear selection material, lack of demonstrated special technical qualification, and the company's commercial background. The balance remuneration was therefore treated as not wholly justified as business expenditure. en-us Sat, 18 Mar 1961 00:00:00 +0530 Mon, 05 Nov 2018 12:59:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276294 Deductibility of remuneration to a technical adviser under section 10(2)(xv) of the Income-tax Act, 1922 depended on whether the expenditure was laid out wholly and exclusively for business purposes. The assessee bore the burden of proving commercial expediency, and reasonableness could not rest on its own assertion alone; revenue authorities were entitled to examine surrounding circumstances. On the facts, the adviser's appointment and payment were influenced by factors such as prior relationships, shareholding position, unclear selection material, lack of demonstrated special technical qualification, and the company's commercial background. The balance remuneration was therefore treated as not wholly justified as business expenditure. Case-Laws Income Tax Sat, 18 Mar 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276294