https://www.taxtmi.com/caselaws?id=17077 The dominant issue was whether dealer's commission/special commission paid by a manufacturer constituted expenditure on "advertisement, publicity and sales promotion" attracting disallowance under s. 37(3A) of the IT Act. The HC held that while "sales promotion" has wide amplitude, the CBDT circular's illustrative categories (e.g., contests, gift offers, free samples) do not include brokerage/commission to commission agents; its omission indicated an intent not to extend "sales promotion" to ordinary selling commissions. Relying on the approach approved in a Cal HC decision, the Court held that brokerage and commission for selling goods do not fall within s. 37(3A), and the disallowance was rejected in favour of the assessee. en-us Wed, 01 Oct 1997 00:00:00 +0530 Mon, 29 Dec 2025 22:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17077 The dominant issue was whether dealer's commission/special commission paid by a manufacturer constituted expenditure on "advertisement, publicity and sales promotion" attracting disallowance under s. 37(3A) of the IT Act. The HC held that while "sales promotion" has wide amplitude, the CBDT circular's illustrative categories (e.g., contests, gift offers, free samples) do not include brokerage/commission to commission agents; its omission indicated an intent not to extend "sales promotion" to ordinary selling commissions. Relying on the approach approved in a Cal HC decision, the Court held that brokerage and commission for selling goods do not fall within s. 37(3A), and the disallowance was rejected in favour of the assessee. Case-Laws Income Tax Wed, 01 Oct 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17077