Supreme Court · 1967 INSC 157 · Decided 19 July 1967

Commissioner of Income-Tax, Gujarat Ahmedabad v. Tejaji Farasram Kharawalla LTD.

Court
Supreme Court of India
Citation
1967 INSC 157 · [1968] 1 S.C.R. 37
Case number
CIVIL APPEAL No. 2162/1966
Decided
19 July 1967
Bench
J.C. SHAH, S.M. SIKRI, V. RAMASWAMI (3-judge bench)
Outcome
Appeal(s) allowed
Case type
Civil
Acts & sections cited
Income Tax Act Section 4(3)(vi)

Headnote

Indian Income-tax .4ct, 1922, s. 4(3) (vi)- Allowance to agent for expenses wholly and necessarily in the performance of duties-­ Exemption under section whether applicable to whole amount st sanctioned whether actually expended or not-'lncurred' whether includes 'to be incurred'. The C by another company. They were paid 7l% on the sales .as sellinll commission and 5')(;. as con_tingency expenses. The question in in .. come-tax proceedings was whether the amount not spent out of the grant for contingency expenses was exempt from taxation by virtue of s. 4(3) (vi) of the

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