https://www.taxtmi.com/highlights?id=102785 Commission payments to agents were allowable as business expenditure where they were intrinsically linked to commission income earned from pharmaceutical companies for facilitating marketing and sales. The disallowance based on an assumption that payments related to direct sales to Government hospitals lacked factual support. Recipient details, tax deduction at source, banking-channel payments and recipients' income-tax returns established the identity of recipients, genuineness of payments and business purpose. With no evidence of fictitious payments, non-existent recipients or diversion back to the assessee, the expenditure satisfied the wholly and exclusively business-purpose test and the disallowance was deleted. en-us Tue, 18 Aug 2026 09:33:01 +0530 Tue, 18 Aug 2026 09:33:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102785 Commission payments to agents were allowable as business expenditure where they were intrinsically linked to commission income earned from pharmaceutical companies for facilitating marketing and sales. The disallowance based on an assumption that payments related to direct sales to Government hospitals lacked factual support. Recipient details, tax deduction at source, banking-channel payments and recipients' income-tax returns established the identity of recipients, genuineness of payments and business purpose. With no evidence of fictitious payments, non-existent recipients or diversion back to the assessee, the expenditure satisfied the wholly and exclusively business-purpose test and the disallowance was deleted. Highlights Income Tax Tue, 18 Aug 2026 09:33:01 +0530 https://www.taxtmi.com/highlights?id=102785