Section 37: Deduction for Commission Expenses Must Align with Income Tax Act Criteria, Not Just Benefit Test.

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....Disallowance of deduction of commission expenses - Although a steep rise of an expenditure during a year would raise serious doubts as regards the genuineness of the claim for deduction of the same by the assessee, but then, as observed by us hereinabove, the allowability or not of the same has to be tested as per the mandate of Section 37 of the Act; and not on the touchstone of satisfaction of the “benefit test” as had been done by the A.O in the present case. - AT....