Commissioner Of Income-Tax vs Assam Frontier Tea Ltd.

The Supreme Court upheld the decision of the High Court affirming the Income-tax Appellate Tribunal's ruling that the assessee is entitled to a weighted deduction under Section 35B(1)(b)(iv) of the Income-tax Act for expenses incurred on a warehouse maintained by an agent abroad for storing tea. The Court clarified that the term 'maintenance of an agency' includes reimbursement of expenses related to the promotion of sales outside India, and the Revenue's argument regarding the warehouse's usage was dismissed as it was not previously raised. The Court reaffirmed the interpretation of Section 35B in line with its earlier judgment in Aravinda Paramila Works v. CIT.