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2020 (11) TMI 1075 - AT - Income TaxGlobal Trade Development expenses (GTD expenses) - Disallowance of the said expenses were not incurred in accordance with the aims and objectives of the appellant society, failing to appreciate the contemporaneous evidences filed on record substantiating the business nexus of said expenditure - HELD THAT:- The assessee has aimed through GTD, issues such as immigration policies, visa regimes, software quality standards. WTO and free trade in services data security and next generation best practices and the importance of collaboration and trade cooperation, especially during these times of economic recession. The assessee is working closely with the Indian Government to represent the true potential of Indian IT Industry for increasing the Indian market share in Information and Communication Technology (ICT) and helping to ensure that the Governments of other nations do not create impediments to free trade or barrier-free business exchanges. GTD expenditure incurred for the above purpose primarily consisted of Consulting fees paid to various international firms in respect of their strategic and tactical planning for positioning IT industry of India vis-a-vis the foreign country's economic outlook, Expenditure on global protectionism sentiments and campaign, Expenditure in public relations/ public awareness and Travelling expenses. We also find that the similar expenses has been allowed in [2019 (5) TMI 1158 - ITAT DELHI] wherein it was held that the disallowance of GTD expenses are not sustainable on the grounds that the purpose of such expenditure and the benefits derivable there from is aimed at benefitting L.C.T & Business Process Management (BPM) industry as a whole, which not denotes the member fraternity of the assessee, but also the industry at large in India. The monetary and in principal support to GTD activity by Government of India clearly establish the utility of such expenses for the India I.T. Industry as a whole. Thus keeping in view the activities of the assessee and its relevance to the expenses incurred, the continuous stand of the revenue to allow such expenses in all the previous and subsequent years, we hereby hold that the disallowance confirmed by the ld. CIT (A) is liable to be quashed. Appeal of the assessee is allowed.
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