1966 (6) TMI 1

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..... ) of the Indian Income-tax Act, 1922, sought by the Commissioner of Income-tax, Bangalore. The assessee is a private limited company carrying on business in mining and exportation of manganese ore. In respect of the assessment year 1961-62, a deduction of Rs. 10,500 was claimed by the assessee. This sum of money, according to the assessee, had been paid to a consultant known as Ibcon (P.) Ltd. whi .....

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..... no doubt in our minds that the question should be answered in favour of the assessee. In Commissioner of Income-tax v. Malayalam Plantations Ltd., the Supreme Court said this when discussing the meaning of the words " for the purpose of such business " occurring in section 10(2)(xv) : "The expression 'for the purpose of the business' is wider in scope than the expression 'for the purpose of earni .....

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..... that appointment was made for the improvement and rationalisation of the assessee's administration. The Income-tax Officer himself had no doubt in his mind that the amount paid to Ibcon (P.) Ltd. was an expenditure wholly and exclusively for the purpose of the business. This is what he said: "There is no doubt that the expense was wholly and exclusively for the purpose of the business." We are n .....

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