TMI Blog2015 (6) TMI 250X X X X Extracts X X X X X X X X Extracts X X X X ..... vity or expenditure cannot be subjected to objective reasonable standard as the AO sought to impose upon it. To that extent, the CIT(Appeals) decision, in the considered view of this Court cannot be faulted. Since the ITAT reconsidered these aspects, no question of law arises - Decided against revenue. Disallowance of advertising expenditure - CIT(A) allowed the claim - Held that:- AO allowed d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te Tribunal (ITAT) dated 31.10.2014 whereby it refused to interfere with the decision of the CIT(A) on two issues. It is contended that the disallowance of management fee made by the AO to the tune of ₹ 1,34,35,168/- was not justified. Likewise, the ITAT's reasoning with respect to advertising expenditure of ₹ 28,74,947/- was also questioned. 2. The assessee started its business ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r Section 37. On these grounds, the said expenditure was allowed. The ITAT confirmed the CIT(Appeals)'s decision. 3. We have considered the submissions. As to whether the expenditure was wholly laid out for the business purpose and was driven by commercial expediency cannot be viewed from a narrow lens of revenue officer's perspective. The element of business activity or expenditure can ..... X X X X Extracts X X X X X X X X Extracts X X X X
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