Tribunal held that it may not be practically possible for all businesses to maintain a complete list of the gifts given to their various customers and demonstrate that a particular sales order was received as a result of a particular gift. The Income-tax Act, 1961 did not prescribe demonstrating such live linkage. In the present case, there was no denial by the Department that the assessee had been carrying on business regularly, the Department also did not allege that there was any personal element involved in the expenditure. In business practice in India customary gifts are usually handed out during festive occasions. Although handing out gold items or semi-precious items may be frowned upon by the Department, all the same it could not be a reason for disallowing the expenditure, especially when the Department could not step into the shoes of a businessman and direct how the business should be conducted. However, the reasonableness of quantum of expenditure vis-a-vis the turnover would have to be justifiable. Accordingly, interest of justice would be served if the disallowance was restricted to 40 per cent. of the initial total disallowance of Rs. 50,32,880. (AY.2012-13)