COMMISSIONER OF INCOME-TAX BOMBAY vs MAHARASHTRA SUGAR MILLS LTD. BOMBAY

The Supreme Court held that under Section 10(2)(xv) of the Income-tax Act, 1922, the entire remuneration paid to managing agents is deductible as it is laid out wholly and exclusively for the purpose of the business, regardless of whether part of the income is not exigible to tax. The Court emphasized that equitable considerations are irrelevant in interpreting tax statutes, and the allowance claimed must be deducted if permissible under the Act. The appeal was dismissed, affirming the lower courts' decisions that upheld the deduction.