https://www.taxtmi.com/caselaws?id=55470 Section 263 revision was not barred by appellate merger because the appellate proceedings had addressed other section 35B expenditure items, not export sales commission; section 35B claims require item-wise consideration. Commission paid to foreign agents qualified for weighted deduction under section 35B(1)(b)(iv), as maintaining an overseas agency includes operating through agents for sales promotion. The provision operated as an export incentive, making restrictive interpretations from other contexts inapplicable. Consequently, withdrawal of the weighted deduction through revision was unjustified and the appeals were allowed. en-us Thu, 20 Sep 1990 00:00:00 +0530 Sat, 27 Nov 2010 12:14:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55470 Section 263 revision was not barred by appellate merger because the appellate proceedings had addressed other section 35B expenditure items, not export sales commission; section 35B claims require item-wise consideration. Commission paid to foreign agents qualified for weighted deduction under section 35B(1)(b)(iv), as maintaining an overseas agency includes operating through agents for sales promotion. The provision operated as an export incentive, making restrictive interpretations from other contexts inapplicable. Consequently, withdrawal of the weighted deduction through revision was unjustified and the appeals were allowed. Case-Laws Income Tax Thu, 20 Sep 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55470