TaxTMI 
TaxTMI 
1981 (12) TMI 74
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....) Inspection & testing 9,412 NIL (v) Insurance charges 7,835 23,321 (vi) Shipping Charges NIL 27,65,271 (vii) Packing and forwarding NIL 2,69,120 (b) Rs. Rs. (i) Office and godown rent 21,666 allowed 4,187 28,466 allowed 3640 (ii) Salaries to staff 43,770 allowed 10,948 51,368 allowed 12,842 (iii) Postage & Telegram 44,634 allowed 17,900 allowed 16,720 (iv) Printing & Stationery 3,387 allowed 1,000 allowed 2,000 (v) Directors Remuneration 1,20,000 allowed 30,000 allowed 30,000 2. The assessee comes up in appeal before us claiming full deduction on those items being pure export house. The Revenue also filed....
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....gn delegations etc. Since it is a joint meeting of both the suppliers and also the buyers, it will be fair and reasonable to allocate allowable deduction under s. 35-B at 50 per cent of the total claim for both the years. The ITO is accordingly directed to allow weighted deduction on 50 per cent of the claim for each of the above two years. 6. The next ground of appeal relates to deductions partially allowed by the CIT on the items listed in para(b) above. With regard to office rent, salaries to staff and Directors' remuneration, the CIT allocated proportionate expenditure between cost of procurement and sales. Accordingly the purchase and sale activities are equally allocated. After such allocation, the CIT (A) treated 25 per cent of 50....
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....s imported from abroad under import entitlements against these exports are also locally sold, the turnover from which was around Rs. 4,93,086 in the year 1975-76. This is about 10 per cent of the total turnover. In the asst. yr. 1976-77, the total turnover was Rs. 1,25,00,000 approximately and local sale was to the tune of Rs. 3,63,000. The percentage of export accounted for more than 90 per cent of the total turnover for these years. The CIT allocated activities of the assessee into two categories, namely, purchase and sale. The activities relateable to purchase and pre-current are considered by him to be not allowable. The balance of the expenditure at 50 per cent of the total expenses on the above account are treated as for the purpose o....
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.... respect of appeals in ITA Nos. 3968 and 3969 (Del) 80. As the weighted deductions were allowed on the basis of the decision of the special Bench of Tribunal in J.H. & Co. The only common ground of appeal is against the order of the CIT (A) directing the allowance of deduction expenses of Rs. 9,296 & 9,249 respectively in addition to its allowance under s. 35-B rightly disallowed by the ITO for the above two years. The CIT while allowing these expenses observed as follows for the asst. yr. 1975-76. "4. In the next ground, the assessee complaint against the disallowance of Rs. 9,296 out of delegation expenses. Earlier in this order the Assessee's claim of weighted deduction in respect of an amount of Rs. 16,371 said to have been incurred ....