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2011 (3) TMI 525 - AT - Income TaxReopening - expenditure of Rs.1.59 crores during Cricket match - Claim of expenditure u/s 37(1) - Held that:- The case of the assessee is that it exports its products to 65 countries, out of which some are cricket loving countries. But even then how promoting bowling activity in one country could affect sales of tyres to other countries. The expenditure incurred towards traffic signals and sponsorship of sports and the like events which has the advertisement value in the form of display of name of boards, hoardings during the events and media advertisement which cannot be connected with the promotion of cricket by way of training of the pace bowlers. - Additions made by AO confirmed. - Decided against the assessee Regarding interest u/s 234D - Held that: This issue stands covered in favour of the assessee by the decision of the ITAT, Delhi in the case of ITO vs Ekta Promoters, Ekta Promoters (2008 -TMI - 65270 - ITAT DELHI-E) Deduction u/s 80IA - manufacture - Crown corks, or other fittings of cork, rubber, polyethylene or any other material - Held that:- There is no dispute between the parties regarding the fact that 'tyre' is a rubber fitting. The material used for tyre is definitely rubber and as per Item No.27 of Eleventh Schedule which prescribes the list of articles or things not eligible for deduction u/s 80IA, disentitles the assessee from this claim. - Benefit of deduction u/s 80IA denied to assesssee.
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