case is really whether
this was done as a measure of commercial expediency.
In our opinion, the decisions relating to Section ... purpose of
business" includes expenditure voluntarily incurred for commercial
expediency, and it is immaterial if a third party also benefits thereby.
Thus in Atherton
lakhs on the ground that
it had not been incurred for commercial expediency. The High
Court also disallowed the annuity paid to the managing
director ... that the sum of
money was expended on the ground of commercial expediency
and in order indirectly to facilitate the carrying on of the
business
order to determine the reasonableness of the
expenditure, the test of commercial expediency would have to
be adjudged from the point of view ... businessman. Even so whatever be the
commercial considerations, it is difficult to hold that the
commercial expediency dictated the assessee Company to allow
itself
paid exgratia would not necessarily mean
that it is unreasonable. Commercial expediency does not
mean that an employer should not make any payment ... entitled to it under a
contract. What is the requirement of commercial expediency
must be judged not in the light of the 19th Century laissez
accepted commercial practice and trading principles. The expenditure must be incidental to the business and must be necessitated or justified by commercial expediency. It must ... times be considered to be commercially expedient. Since commercial men are best experienced in commercial expediency, we are prepared to proceed on the basis that
assessee had agreed to forgo the amounts on grounds of commercial expediency. The Income-tax Officer held that the managed company had earned a substantial ... remuneration was done by the assessee for reasons of commercial expediency, as the managed company had suffered losses in the past and had been carrying
amount forgone by the assessee company was on the ground of commercial expediency or not was regarded as one of importance by the Court ... given up for reasons of commercial expediency. If the amount was given up for reasons of commercial expediency, then we have already held that
agreement with the minors was made not for reasons of commercial expediency or legitimate business needs, but for purely diversion of profits, and that ... held :
" Even so whatever be the commercial considerations, it is difficult to hold that the commercial expediency dictated the assessed-company to allow itself
company that the amount had been paid as a matter of commercial expediency and in the interest of the assesee-company as an inducement ... employer is a payment made out of commercial considerations and or commercial expediency. To have a body of contented and loyal workers, ready
loan was given by the assessee as a matter of
commercial expediency; that the expression
"commercial expediency" is one of wide import ... business
expenditure, if it was incurred on grounds of
commercial expediency. In the present case, the AO
as observed by the learned
