9911796707
TMI Blog1994 (10) TMI 47X X X X Extracts X X X X X X X X Extracts X X X X ..... hich the Revenue sought reference to this court, question No. 1 has already been referred under section 256(1). Question No. 2 is one on which we have directed reference in similar other cases. So far as question No. 3 is concerned, the facts are that the assessee had paid commission to certain persons for procuring orders for its products. The payments were made after the sales were effected. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs from prospective customers and brought about sales. The payment is made only if and when the sales are effected, and not otherwise. They are related only to sales. The position of the representatives is that of mere agents canvassing orders, who are remunerated according to the work done and orders procured by them. No doubt, it is intended to enhance and improve the business and sales of the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion No. 2 sought by the Revenue) for the opinion of this court under section 256(2) of the Income-tax Act, 1961, namely : " Whether, on the facts and in the circumstances of the case, the assessee is entitled to investment allowance under section 32A of the Income-tax Act, 1961 ?" Communicate a copy of this judgment under the seal of this court and the signature of the Registrar to the Income-ta ..... X X X X Extracts X X X X X X X X Extracts X X X X
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