The Assessing Officer disallowed 10 per cent. of the commission expenditure on an ad hoc basis. The Tribunal, following its earlier decision in the assessee’s own case, held that commission payments formed an integral part of telecommunication business operations and there was no justification for the disallowance. The deletion by the Commissioner (Appeals) was upheld. Following earlier decisions in the assessee’s own case and in the case of its sister concern, the Tribunal held that royalty, Wireless Planning Commission charges and advertisement expenditure were allowable as revenue expenditure. The Revenue’s appeals were dismissed by applying the principle of judicial consistency  (AY. 1999-2000 & 2007-08).