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2011 (6) TMI 2 - HC - Income TaxDis allowance - Commission paid to DSA - TDuring the instant assessment year, the appellant had incurred an expenditure of Rs. 52,70,636/- on account of commission paid to the Direct Selling Agents (DSA) for their services in sourcing hirers in the year in which the loan is disbursed and debited its Profit & Loss account by a sum of Rs. 48,38,636/- for the purpose of accounting was treated as deferred revenue expenditure. The appellant claimed a deduction on entire sum of Rs. 52,70,636/- incurred during the year as a deduction on the ground that the expenditure was incurred during the year and being revenue in nature, is fully allowable as deduction. - ITAT remitted the matter with direction - Held that: - After stating the principle on which commission paid by the assessee to DSAs would be treated as expenditure relating to particular areas, for want of sufficient evidence to arrive at a definite finding in this behalf, the Tribunal, in its discretion, remitted the case back to the AO giving clear guidelines how to examine the issue on the basis of records to be produced and what course of action, the AO was supposed to take. - Decided against the assessee.
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