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2014 (4) TMI 270 - ITAT DELHIDeletion of addition of advertisement expenses – Assessee engaged in trading of computers and electronic products - Held that:- The assessee had claimed expenditure on account of advertisement and marketing - the assessee furnished ledger account supported by vouchers - Relying upon CIT Vs. Citi Financial Consumer Fin. Ltd. (Delhi) [2011 (3) TMI 622 - Delhi High Court] - expenditure on publicity and advertisement is to be treated as revenue in nature allowable fully in the year it was incurred - the ingredients of section 37 of the Act stand satisfied - normally the expenditure is to be allowed as business expenditure in the year in question in which the same is incurred - there is no advantage which has accrued to the assessee in the capital field - The expenditure was incurred to facilitate the assessee’s trading operations - No fixed capital was created by this expenditure - in the income-tax law, there is no concept of deferred revenue expenditure. Once the assessee claims the deduction for the whole amount of such expenditure, even in the year in which it is incurred, and the expenditure fulfils the test laid down u/s 37 of the Act, it has to be allowed - The AO erred in holding that the advertisement expenses as deferred revenue expenses is not valid in the eyes of law and therefore the CIT(A) has rightly set aside the same – thus, there is no infirmity in the findings of the CIT(A) – Decided against Revenue.
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