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2009 (4) TMI 1 - DELHI HIGH COURTAssessee-company develop/manage franchisees for running restaurants – assessee created an intermediary in the form of a wholly owned subsidiary, to carry on a “co-operative advertising” on the behalf of its franchisees - claim on account of accrued marketing expenditure and on account of contributions towards advertising, marketing and promotional activities towards wholly owned subsidiary – not proved that expenditure were on account of commercial expediency so rightly disallowed by tribunal
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