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2018 (3) TMI 464 - AT - Income TaxDisallowance of advertisement expenditure incurred on the project known as “Atlantis” - Held that:-It is also not in dispute that the assessee developed several projects. One among them is known as “Atlantis”. When the assessee made advertisements, as claimed by the assessee in its written submission, it displayed the name of the concern, name of the projects, brand name, etc. Such advertisements will definitely promote not only the projects developed by the assessee but also the image and goodwill of the assessee-company among the general public. Therefore, the cost of expenditure cannot be related to a particular project which is undertaken by the assessee in a particular year. At the best, it can be relatable to the year in which the advertisement was made. Merely because the assessee segregated the cost of expenditure in relation to a particular project and later stage claimed as general advertisement expenditure that may not alter the character of the advertisement expenditure incurred by the assessee. As long as the expenditure on the advertisement made during the year under consideration is not in dispute, it cannot be disallowed by the Assessing Officer on the ground that no income was disclosed in respect of a particular project known as “Atlantis”. Hence, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee - Decided against revenue
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