1967 (12) TMI 8

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....nder section 10(2)(xv) of the Income-tax Act, 1922, a sum of Rs. 13,376 as expenditure laid but wholly and exclusively for purposes of the business. The claim was disallowed by the Income-tax Officer, who was of the view that the sum was not expended for commercial expediency. The Appellate Assistant Commissioner, however, agreed with the assessee, being of opinion that the expenditure was a norma....

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....h 15% was payable. If the collections exceeded that figure, 50% was agreed to be paid. It appears the picture ran for 25 weeks and that was the occasion for celebration of the Silver Jubilee. The expenditure sought to be deducted related to the celebration. The Tribunal thought that there was no causal connection between the expenditure and the taking of further leases of the picture or collection....

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....eks of exhibition from the point of view of the assessee was an important occasion in carrying on the business which required celebration. Evidently, the object of the celebration was publicity, and that publicity would only have been with a view to step up the collections, at a time when the collections might otherwise be dwindling. It has been pointed out by courts repeatedly that the expediency....