COMMISSIONER OF INCOME TAX, DELHI vs STEPWELL INDUSTRIES LTD.

The Supreme Court addressed the interpretation of Section 35B of the Income Tax Act, 1961, determining that the assessee is not entitled to a weighted deduction for commission payments made for activities outside India unless it can be proven that such activities were conducted on behalf of the assessee and pertained to goods or services provided by the assessee. The Court held that the High Court should have referred the question to it, but instead treated it as a reference and answered in the negative, favoring the Revenue. The appeal was allowed without costs.