Dipak Kumar Sen, J. - (1.) Madhu Jayanti (Pvt.) Ltd., the assessee, carries on business, inter alia, in the manufacture and export of tea. In the assessment year 1975-76, the corresponding previous year being the one ended on December 31, 1974, the assessee in its revised return for income-tax claimed weighted deduction for export markets development allowance under Section 35B of the I.T. Act, 1961, in respect of its export promotion expenses under the following four heads : (a) Air freight on parcels for samples ; (b) Commission paid in foreign countries to agents to obtain orders ; (c) Steamer freight on export consignments ; (d) Premium paid to the Export Credit Guarantee Corporation.
(2.) The ITO allowed deduction as claimed on the air freight and commission but disallowed the claim for deduction in respect of steamer freight and the premium paid to the Export Credit Guarantee Corporation.
(3.) The assessee preferred an appeal before the AAC against the disallowance of the deduction claimed for the said items. In the appeal, the assessee claimed further deduction under Section 35B of the I.T. Act, in respect of the following further heads : (a) Agency commission paid from the Cochin branch of the assessee ; (b) Inspection and sampling charges ; (c) Telex charges ; (d) Packing expenses ; (e) Bank interest ; (f) Shipping expenses.;