2004 (8) TMI 43

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed from the Central Government, the assessee had incurred expenses of Rs. 2,37,000 which was paid to the commission agent. The Assessing Officer had disallowed a sum of Rs. 1,23,130 out of the aforesaid amount on the ground that it is excessive payment. The Commissioner of Income-tax (Appeals), however, deleted the disallowance. The Tribunal upheld the order of the Commissioner of Income-tax (Appe....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....erson or a middle man, it cannot be said that the expenditure has not been laid out for the purpose of business. Moreover, the nature of expenditure has to be seen from the view point of the assessee and the Assessing Officer has neither the expertise of running a business nor has any specialisation to sit in judgment over the assessee as to whether such an expenditure was incurred for commercial ....