2006 (8) TMI 103

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....evenue, has referred the following question for the opinion of this Court: "Whether, on the facts and circumstances of the case, the Appellate Tribunal was justified in law in holding that the expenditure of Rs.12,86,711 in Assessment Year 1984-85 and Rs.13,13,975 in Assessment Year 1985-86 incurred on payment of commission on sales cannot be treated as sales promotion expenses, and, therefore, c....

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....Income Tax Act for it was not an expenditure falling within the mischief of sales promotion. The submission did not find favour with the Assessing Officer and as the appeal was allowed, the Revenue took up the matter before the Tribunal. The Commissioner of Income Tax (Appeals) held that the sales commission could not be aggregated for the purpose of working of the disallowance under Section-37(3A....