In both these appeals point is same i.e. whether assessee is entitled to deduction of 50 per cent of commission received from Life Insurance Corporation. assessee had made application to ITO to grant deduction in respect of rate of 50 per cent. ITO vide his order dt. 2nd July, 1985 allowed deduction at rate of 50 per cent on first year's commission only. Before AAC it was argued that assessee is entitled to 50per cent on entire commission received during year which includes first year's commission as well as renewal commission, relying upon CBDT Circular No. 168/9/93-IT(AI) dt. 6th Jan., 1984. AAC however held that rate of 50 per cent is applicable only to first year's commission and not to renewal commission and dismissed assessee's appeal. Board's circular on which reliance has been placed is follows: "Attention is invited to Board Circular dt. 14th Sept., 1965 issued from Form No. 14/9/65-IT (A & I) on subject. It has been mentioned in that instruction, inter alia, that where detailed accounts regarding expenses incurred by insurance agents are not maintained, ad hoc deduction for expenses at rate of 40per cent of first year's commission should be allowed. ceiling of Rs. 6,000 in respect of such expenditure where gross insurance commission do not exceed Rs. 20,000 was laid down and discretion to grant larger allowance not exceeding Rs. 10,000 in special circumstances was explained in detail. Board has been receiving representations that rate of deduction should be raised from 40per cent having regard to increase in costs. Board has considered these representations and has decided that expenditure m y by all-owned @ 50per cent of year's commission where gross commission is less than Rs. 60,000. above instructions of 22nd Sept., 1965 are modified to this extent". On behalf of assessee Shri Divatia argued that above second para mentions "year's commission" and not first year's commission. Therefore, according to him full play should be given to these words and assessee's right under that circular should not be whittled down. ld. departmental representative however pointed out that first para quoted above refers to first year's commission and second para should b e read in continuation thereof making obvious reference only to first year's commission. Shri Divatia in reply relied upon Circular letter dt. 20th March, 1985 from LIC to various agents where it has been stated that according to aforesaid CBDT Circular agents would be entitled to 50per cent deduction of total commission of whole year which would include renewal commission. Now, circular has to be read as whole. second para cannot be separated from first para. In first para, there is clear reference to first year's commission. Therefore reference in second para to "year's commission" must necessarily mean first year's commission and not renewal commission. Whatever LIC might have written to its agents that cannot influence decision of Tribunal. Therefore, AAC's order is confirmed. appeal are rejected. *** T. S. BHAGATWALA v. INCOME TAX OFFICER