1987 (3) TMI 131

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..... rant deduction in respect of the rate of 50 per cent. The ITO vide his order dt. 2nd July, 1985 allowed the deduction at the rate of 50 per cent on the first year's commission only. 2. Before the AAC it was argued that the assessee is entitled to 50per cent on the entire commission received during the year which includes the first year's commission as well as the renewal commission, relying upo .....

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..... 0,000 was laid down and the discretion to grant a larger allowance not exceeding Rs. 10,000 in special circumstances was explained in detail. The Board has been receiving representations that the rate of deduction should be raised from 40per cent having regard to the increase in costs. The Board has considered these representations and has decided that expenditure may by all-owned @ 50per cent .....

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..... agents where it has been stated that according to the aforesaid CBDT Circular the agents would be entitled to 50per cent deduction of the total commission of the whole year which would include the renewal commission. 7. Now, the circular has to be read as a whole. The second para cannot be separated from the first para. In the first para, there is a clear reference to the first year's commissio .....

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