1987 (3) TMI 131

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....the Life Insurance Corporation. The assessee had made an application to the ITO to grant deduction in respect of the rate of 50 per cent. The ITO vide his order dt. 2nd July, 1985 allowed the deduction at the rate of 50 per cent on the first year's commission only. 2. Before the AAC it was argued that the assessee is entitled to 50per cent on the entire commission received during the year which....

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....respect of such expenditure where the gross insurance commission do not exceed Rs. 20,000 was laid down and the discretion to grant a larger allowance not exceeding Rs. 10,000 in special circumstances was explained in detail. The Board has been receiving representations that the rate of deduction should be raised from 40per cent having regard to the increase in costs. The Board has considered t....

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....ly relied upon the Circular letter dt. 20th March, 1985 from the LIC to the various agents where it has been stated that according to the aforesaid CBDT Circular the agents would be entitled to 50per cent deduction of the total commission of the whole year which would include the renewal commission. 7. Now, the circular has to be read as a whole. The second para cannot be separated from the fir....