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S. A. Builders Ltd. .. Petitioner vs Commissioner Of Income Tax (Appeals) ... on 14 December, 2006

20. Learned ASG mainly relied upon the decision of the Apex Court in case of S.A.Builders vs. Commissioner of Income Tax (Appeals) reported in 2007(1)SCC 781 and more particularly the observations made at paragraphs No.24 to 27 in the said Judgment and contended that it was within the powers of an assessing officer to decide that whether there was any commercial expediency for incurring a particular expenditure and therefore, the action could not be said to be wholly without jurisdiction or ultravires to his power if the assessing officer has disallowed the fee.
Supreme Court of India Cites 12 - Cited by 1104 - M Katju - Full Document

Eastern Investments Ltd vs Commissioner Of Income-Tax,West ... on 4 May, 1951

25. Thus, in Atherton v.British Insulated & Helsby Cables Ltd. it was held by the House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit but voluntarily and on grounds of commercial expediency and in order to indirectly facilitate the carrying on of the business. The above test in Atherton case has been approved by this Court in several decisions eg. Eastern Investments Ltd., vs. CIT, CIT vs. Chandulal Keshavalal & Co., etc...
Supreme Court of India Cites 6 - Cited by 340 - V Bose - Full Document
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