Revenue cannot decide what is ‘commercial expediency’ for Business

DCIT Vs Deloitee Haskins and Sells (ITAT Ahmedabad) The first controversy that arises for our adjudication whether the interest free advances were given by the assessee to its group concern as a measure of commercial expediency in the given facts and circumstances. The expression “commercial expediency” refers to those transactions/ expenditures which are not required to be incurred under any provisions of the law. But it refers to such expenditure, a prudent businessman incurs for the purpose of business. Such expenditures might not have been incurred under any legal obligation, b...