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2009 (1) TMI 13 - HC - Income TaxTribunal allowing deduction of “export commission” to the assessee u/s 37(1), allowing depreciation to the assessee on “training fee”, allowing deduction of lump sum “prepayment premium” paid by the assessee to IDBI - once it is held that services had been rendered by the agent the quantum of commission that has to be paid is purely the discretion of the assessee over which the Revenue cannot sit on judgment – in all aspects, Tribunal has returned pure findings of fact which are not perverse
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