https://www.taxtmi.com/caselaws?id=38476 Disallowance of part of remuneration was examined under the test whether expenditure was laid out wholly and exclusively for business; if not, deduction under the general business expenditure rule is impermissible and section 40(c)(i) may support disallowance. The Tribunal was competent to decide issues of law and fact beyond the precise grounds before the departmental authority when those issues determined the assessment, and on the facts (related-party payments and nature of services) a partial disallowance was a permissible, non-perverse conclusion in favour of the revenue. en-us Wed, 27 Nov 1974 00:00:00 +0530 Sat, 17 Jan 2026 10:51:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38476 Disallowance of part of remuneration was examined under the test whether expenditure was laid out wholly and exclusively for business; if not, deduction under the general business expenditure rule is impermissible and section 40(c)(i) may support disallowance. The Tribunal was competent to decide issues of law and fact beyond the precise grounds before the departmental authority when those issues determined the assessment, and on the facts (related-party payments and nature of services) a partial disallowance was a permissible, non-perverse conclusion in favour of the revenue. Case-Laws Income Tax Wed, 27 Nov 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38476