DCIT v. Ganges International (P.) Ltd. (2021) 190 ITD 755/ ( 2022) 95 ITR 161 (Chennai)(Trib.)

S. 37(1) : Business expenditure-Commission-Foreign agents and local agents-Held to be allowable.

Held that the commission agent had introduced new customers to assessee, procured export order and, accordingly, assessee carried out business and, thus, there was a direct nexus between income generated and commission payment.   Agreements between assessee and agents were duly signed and accepted by respective parties and, assessee had also furnished copies of commercial Invoice, confirmation of accounts, copy of Form 15CB in case of foreign party and in case of Indian company, TDS was deducted, addition on account of disallowance of commission was held to be not justified. (AY. 2016-17)