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Pfizer Limited Versus Asstt. Commissioner of Income Tax, Range–8 (2) , Mumbai and Dy. Commissioner of Income Tax Versus Pfizer Limited

2015 (11) TMI 1697 - ITAT MUMBAI

Transfer pricing adjustment - international transactions between the assessee and its A.E. towards provisions of clinical study management and monitoring support services - selection of comparable - Held that:- The assessee company is engaged in manufacturing and sale of pharmaceutical products, thus companies functionally dissimilar with that of assessee need to be deselected from final list of comparable. - Disallowance of depreciation claimed on assets of Ankleshwar plant allowed as decid .....

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nchan Kaushal a/w Shri Aliasger Rampurwala and Ms. Chandani Shah Revenue : Shri N.K. Chand ORDER PER SAKTIJIT DEY, J.M. These cross appeals are against the order dated 30th January 2008, passed by the learned Commissioner (Appeals)-32, Mumbai, for the assessment year 2003-04. 2. We first proceed to dispose of assessee s appeal in ITA no.3729/Mum./2008, for the assessment year 2003-04. In this appeal, the assessee in total has raised nine grounds as per the concise grounds of appeal. 3. Ground no .....

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o the international transactions between the assessee and its A.E. towards provisions of clinical study management and monitoring support services. 6. Briefly stated the facts relating to the issue are, the assessee company is engaged in manufacturing and sale of pharmaceutical products. As as per the share holding pattern Pfizer Inc., holds 40% of the equity share capital in the assessee company and rest of the share capital is held by others. Thus, the assessee and Pfizer Inc., are Associate E .....

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ith OP/OC as Profit Level Indicator (PLI). By adopting this method, assessee had selected six companies as comparable. By considering preceding three years financialS average operating margin of comparables was found to be 12.61% as against assessee s margin of 11.11%. Hence, the price charged was considered to be within arm s length. The Transfer Pricing Officer observed, the role played by the assessee in the transaction with A.E. is not in the nature of routine support or general services pro .....

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by the assessee are distinctly different to the comparable companies selected by the assessee. He, therefore, proceeded to identify companies which are more functionally similar to the assessee. Thus, the Assessing Officer rejecting four companies out of six selected by the assessee, proceeded to select some more comparable companies on his own. By conducting search in data bases, he selected the following companies as comparable:- Sr. no. Name of the Company Operating Profit to Cost 1. Hinduja .....

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n terms with the order passed by the Transfer Pricing Officer, the Assessing Officer completed the assessment by incorporating the transfer pricing adjustment recommended by him. 9. Before the first appellate authority, the assessee challenged both selection as well as rejection of comparables by the Transfer Pricing Officer. The learned Commissioner (Appeals) after considering the submissions of the assessee, upheld selection of SIRO Clinpharm Pvt. Ltd., Vimta Labs Ltd. and Choksi Laboratory Lt .....

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s. 10. The learned Counsel for the assessee submitted before us the clinical research trial done on behalf of the A.E. is as a facilitator. It was submitted, for this purpose the assessee has identified certain hospitals which undertake such clinical research trial activity and the assessee never does it on its own. It was submitted, for carrying out such activity, assessee neither has any infrastructure, man power or the asset. He, therefore, submitted while selecting the comparable companies, .....

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ered as a comparable. In this context, he specifically referred to the judgment dated 10th August 2005, of Hon'ble Delhi High Court in Ramp Green Solutions Pvt. Ltd. v/s CIT, ITA no.201 of 2015. 12. As far as Vimta Laboratory Ltd. and Choksi Ltd. are concerned, the learned Counsel for the assessee advancing similar arguments submitted, business model of these companies are not similar to the assessee as Choksi Ltd. is doing clinical research activities itself whereas Vimta Labs Ltd. is engag .....

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by the Transfer Pricing Officer was also placed on record. He, therefore, submitted that these three companies are required to be excluded from list of comparables. 13. The learned Departmental Representative strongly objecting to the contention of assessee s counsel submitted, SIRO Clinpharm Pvt. Ltd. was held as a comparable by the Tribunal in assessee s own case for the assessment year 2002-03 in ITA no.3098/Mum./2006 dated 8th March 2013. In this context, he drew our attention to Para-17 of .....

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acted as a facilitator between the A.E. and the hospital which are carrying out clinical research. It was submitted the assessee is not simply outsourcing its activities to the hospitals but clearly monitors it. In every stage of the clinical trial, there is interaction between the doctors and assessee s personnel. Therefore, there is a value addition by the assessee. Taking us through various clauses of the agreement, the learned Departmental Representative submitted, there is continuous inter .....

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. Referring to the order of the Transfer Pricing Officer, the learned Departmental Representative submitted, Transfer Pricing Officer has included both high margin and low margin companies even though they are not functionally similar. He submitted when the assessee has no issue with low margin companies which are not functionally similar to the assessee, there should not be any grievance for inclusion of high margin companies only on the allegation that they are functionally dissimilar. He subm .....

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ment year 2002-03, the Tribunal has retained SIRO Clinpharm Pvt. Ltd. as a comparable, but referring to the observations made by the Tribunal he submitted, the Bench has recorded a finding that business model of two companies are different as SIRO Clinpharm Pvt. Ltd., is doing such activities on its own whereas, the assessee is out sourcing it. The learned Counsel for the assessee submitted, as the Tribunal has itself recorded the finding that business model of SIRO Clinpharm Pvt. Ltd. is differ .....

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ently, on the basis of data available in public domain, if it is found that these two companies are not functionally similar, the assessee cannot be precluded from objecting to selection of these companies. He, therefore, submitted that these companies cannot be considered as comparable. 16. We have considered the submissions of the parties, perused the orders of the Departmental Authorities and the material available on record. As could be seen, the issue in dispute in the aforesaid grounds rel .....

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assessee cannot be considered to be acting as mere facilitator but has actually rendered value addition to the clinical research trial, however, no substantive evidence has been brought on record to prove such facts. As it appears, the assessee has entered into agreement with hospitals for conducting the clinical research trial and the entire process of clinical research trial was conducted by the hospital. Whereas, SIRO Clinpharm Pvt. Ltd. conducts the clinical research trial activities itself .....

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. is doing the clinical trial on its own, whereas, the assessee is getting the clinical trial done from third party. As could be seen, the aforesaid finding of the co-ordinate bench in the immediately preceding assessment year is upon considering the same service agreement between the related parties as well as similar nature of activity. The Department has not brought any material on record to demonstrate that the nature of activity in the impugned assessment year is in any way different from t .....

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he observations of the Hon'ble Delhi High Court in the referred judgment as under:- 20. In order for the benchmarking studies to be reliable for the purposes of determining the ALP, it would be essential that the entities selected as comparables are functionally similar and are subject to the similar business environment and risks as the tested party. In order to impute an ALP to a controlled transaction, it would be essential to ensure that the instances of uncontrolled entities/transaction .....

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he value addition in respect of products and services provided by parties; the business model; and the assets and resources employed. It cannot be disputed that the functions performed by an entity would have a material bearing on the value and profitability of the entity. It is, therefore, obvious that the comparables selected and the tested party must be functionally similar for ascertaining a reliable ALP by TNMM. Rule 10B(2) of the Income Tax Rules, 1962 also clearly indicates that the compa .....

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include comparables which are similar in all aspects that have a material bearing on their profitability. Paragraph 1.36 of the "OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations" published in 2010 (hereafter 'OECD Guidelines') indicates the "comparability factors" which are important while considering the comparability of uncontrolled transactions/entities with the controlled transactions/entities. Sub-rule (2) of rule 10B of the .....

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Tribunal noted that Vishal and eClerx were both engaged in rendering ITeS. The Tribunal held that, "once a service falls under the category of ITeS, then there is no sub-classification of segment". Thus, according to the Tribunal, no differentiation could be made between the entities rendering ITeS. We find it difficult to accept this view as it is contrary to the fundamental rationale of determining ALP by comparing controlled transactions/entities with similar uncontrolled transactio .....

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Further, both service providers cannot be considered to be functionally similar. Their business environment would be entirely different, the demand and supply for the services would be different, the assets and capital employed would differ, the competence required to operate the two services would be different. Each of the aforesaid factors would have a material bearing on the profitability of the two entities. Treating the said entities to be comparables only for the reason that they use Info .....

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raction of the proportionate cost incurred by the Assessee, apparently, for the reason that most of its work was outsourced to other vendors/service providers. The DRP and the Tribunal erred in brushing aside this vital difference by observing that outsourcing was common in ITeS industry and the same would not have a bearing on profitability. Plainly, a business model where services are rendered by employing own employees and using one s own infrastructure would have a different cost structure a .....

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to the assessee in all respect as this company renders the services on its own without outsourcing, unlike the assessee. Though, it may be a fact that Tribunal in the preceding assessment year has accepted this company as comparable to the assessee, but the Tribunal did not had the benefit of principle laid down by the Hon'ble Delhi High Court in Ramp Green Solutions Pvt. Ltd. (supra). In view of the aforesaid, respectfully following the decision of the Hon'ble Delhi High Court in Ramp .....

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e assessee as it was out sourcing its activities. Hence, the business model is different. Reverse is the case with the assessee. While the assessee is out sourcing its clinical research trial activities, the comparable company is doing the activity itself. Thus, the business model of the assessee and comparable company are not same. Though, learned Departmental Representative has raised serious objection with regard to exclusion of this company by submitting that assessee itself in its transfer .....

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ain, it was found that this company is not a comparable. In our view, the aforesaid explanation of the assessee deserves to be accepted. We, therefore, direct the Assessing Officer to exclude this company as comparable. 19. As far as Vimta Lab Ltd. is concerned, apart from the fact that business model of this company is different from assessee as demonstrated by the learned Counsel for the assessee, from the material on record it is also seen that the Transfer Pricing Officer himself in assessme .....

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ssessee had shown cost on clinical support services under various heads at Rs.Rs. 16,50,21,000. Though, as per assessee the total operating cost shown consists of direct and indirect costs but the Transfer Pricing Officer was under an impression that the total cost represents only direct costs. Referring to the agreement with A.E., he observed, as per the terms of agreement, the assessee is required to recover indirect costs from the A.E. but the assessee has not done so. Though, the assessee co .....

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nd favour with him. 22. The learned Counsel for the assessee submitted before us, identical issue came up for consideration before the Tribunal in assessee s own case for the assessment year 2002-03 in ITA no.3098/Mum./2006, dated 8th March 2013. Referring to the findings of the Tribunal in Para-24 of the order, he requested for remitting the matter to the Assessing Officer for necessary verification in terms of the said direction. 23. The learned Departmental Representative has no objection to .....

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he assessee on this issue that if the indirect cost was already included by the assessee in the total cost of ₹ 1080.25 Lakhs incurred in relation to the services provided to its AE for applying the mark up of 10%, there is no justification in adding indirect cost @ 5% of the direct cost separately as done by the authorities below relying on the terms of the relevant agreement. However, as submitted by the ld. DR, the stand taken by the assessee about inclusion of indirect cost of ₹ .....

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assessee that indirect cost of ₹ 285.48 Lakhs was already included in the total cost of ₹ 1080.25 Lakhs and if the same is found to be correct, the AO is directed not to add separately indirect cost @ 5% of the direct cost for the purpose of Transfer Pricing exercise. Ground No. 2(d) is accordingly treated as allowed for statistical purposes. 25. The fact and issue being materially same, respectfully following the aforesaid decision of the Tribunal in assessee s own case, we remit t .....

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India, which is raised in grounds no.4 and 5 of concise ground. However, subsequently, the assessee on 20th April 2010, has sought permission to raise following additional grounds related to this issue. Without prejudice to ground no.4 to 6 of the concise ground filed on May 18, 2010, appellant submits that resale price method be considered as most appropriate method for determining the arm s length price. The appellant prays that the international transaction of import of FDFs for resale of Ind .....

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propriate method for computing the arm's length price is re-sale price method (RSPM). He submitted, though, the assessee in transfer pricing study has adopted TNMM as the most appropriate method but that will not preclude the assessee from raising the plea that the most appropriate method for computing the arm's length price is re-sale price method, if otherwise it is applicable to the particular international transaction and is in conformity with the relevant statutory provisions. The l .....

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llate stage. He submitted, as per the relevant provisions contained under the Income Tax Act, and the rules, the most appropriate method in case of this particular transaction between the assessee and its A.E. is re-sale price method as the assessee simply imports the goods from its A.E. and sells them to customers in India. For the aforesaid proposition, he relied upon a number of decisions of the Tribunal as well as Hon'ble Jurisdictional High Court which are as under:- i) CÏT v/s L&O .....

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ing to assessee s transaction with the A.E. in respect of import of FDFs are available on record, and the issue raised can be decided on the basis of such available material the additional ground can be entertained. 30. The learned Departmental Representative strongly opposing the contention of the assessee s counsel submitted, while preparing the transfer pricing study, the assessee itself has rejected re-sale price method by giving certain reasons which are specifically mentioned in the transf .....

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be entertained when basic facts relating to comparability analysis are not available. Referring to the decision of the Hon'ble Supreme Court in National Thermal Power Co. Pvt. Ltd. (supra), the learned Departmental Representative submitted, only when the basic facts relating to the issue raised in the additional ground are available on record before the Assessing Officer, then only it can be entertained. He submitted, as per the principle laid down by Hon'ble Supreme Court only pure ques .....

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at it is creating marketing intangible by incurring substantial expenses on marketing. Referring to certain OECD guidelines, the learned Departmental Representative submitted, as enquiry into marketing functions is a factual enquiry this issue cannot be entertained at this stage. He submitted, though the Transfer Pricing Officer has not dealt with the issue of advertisement and marketing expenses incurred by the assessee separately but still this has to be kept in mind while taking a decision as .....

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o consider RSPM as the most appropriate method, the assessee cannot be precluded from raising its plea for considering RSPM as most appropriate method. It was submitted, as per the transfer pricing provisions, arm's length price has to be determined by applying the most appropriate method. Considering the nature of transaction, if it is found that RSPM is the most appropriate method even if the assessee had selected some other method the Assessing Officer / Transfer Pricing Officer is entitl .....

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hod which is a purely legal issue can be entertained by way of additional ground. He submitted only after applicability of most appropriate method is decided, issue of selection of comparable will come which can be examined by the Transfer Pricing Officer by verifying the data available in public domain. 33. We have considered the submissions of the parties, perused the orders of the departmental authorities as well as the material available on record. We have also carefully applied our mind to .....

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pt the objection of the learned Departmental Representative. On a perusal of the order passed by the Transfer Pricing Officer under section 92CA, as well as other material on record, it is very much evident that the assessee has produced all relevant documents such as agreement, invoices and all other relevant details in relation to its transactions with A.E. for import of FDFs for re-sale / distribution in India. On a perusal of the provisions contained under section 92C r/w rule 10B, it is cle .....

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aining to import of FDFs from the A.E. are available on record of the Departmental Authorities. Therefore, as far as selection of most appropriate method is concerned, the primary facts are available on record. Therefore, the issue as to what is the most appropriate method is a purely legal issue which can be decided by analyzing the nature of transaction on the basis of primary facts available on record before the Assessing Officer / Transfer Pricing Officer. As far as selection of comparables .....

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r material on record, it is observed that the assessee claimed that it re-sells / distributes the FDFs imported from its A.E. without making any value addition. Therefore, it simply acts like a trader. If the assessee can prove this fact with supporting documentary evidence, then in our view re-sale price method can be considered to be the most appropriate method as assessee is supposed to be engaged in a purely trading activity. The decision relied upon by the learned Counsel for the assessee o .....

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ns is to determine the correct arm's length price by applying the most appropriate method. However, considering the fact that the assessee has not raised this issue either before the Transfer Pricing Officer or before the first appellate authority, and has raised if for the first time before the Tribunal by way of additional ground, to give a far opportunity to the department, we are inclined to restore the issue raised in the addition ground to the file of the Assessing Officer / Transfer P .....

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he Assessing Officer / Transfer Pricing Officer must afford reasonable opportunity of being heard to the assessee in the matter. With the aforesaid observations, we allow the additional ground for statistical purposes. 34. In view of our aforesaid decision, the issue raised in grounds no.4 and 5, have become redundant. However, the assessee is at liberty to raise these issues before the Assessing Officer / Transfer Pricing Officer or before the appellate forum depending upon the decision to be t .....

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m of depreciation should not be disallowed. Though, the assessee submitted that once the assets form part of the block, it losses its individual character, hence, depreciation on such individual asset cannot be disallowed but the Assessing Officer mentioning that similar disallowance was made in assessment year 2000-01 disallowed depreciation relating to Ankleshwar plant at ₹ 32,87,058. The assessee challenged the disallowance before the first appellate authority. 37. The learned Commissio .....

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factual position. 40. We have considered the submissions of the parties and perused the material available on record. As far as the factual aspect of the issue is concerned, there is no dispute that assessee has claimed depreciation on block of asset which also includes assets of Ankleshwar plants. It is observed, when identical issue of disallowance of depreciation on the assets of Ankleshwar plants came up for consideration before the Tribunal, Mumbai Bench, in assessee s own case for the asse .....

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on by deleting the addition made by the Assessing Officer. 41. The next issue, as raised in ground no.8, relates to the decision of the Departmental Authorities in treating the income from sub-leasing of property as income from business as against assessee s claim of house property income. 42. Briefly stated the facts are, the Assessing Officer noticing that the assessee has shown the amount received on sub-leasing of office premise as house property income called upon the assessee to explain wh .....

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t year 2002-03, similar view was expressed by the first appellate authority. The learned Counsel for the assessee submitted before us that issue in dispute stands squarely covered in its favour not only by the decision of the Tribunal in assessee s own case for the assessment year 2002-03 but by the Hon'ble Jurisdictional High Court in assessee s own case for assessment year 2000-01 and 2001-02. 43. The learned Departmental Representative has not controverted the aforesaid factual position. .....

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sessment year. It is further evident, the Hon'ble Jurisdictional High Court has approved such view of the Tribunal taken in assessment year 2000-01 and 2001-02 in ITA no.128/2009 and 6776/201. In view of such uncontroverted factual position, following the decision of the co-ordinate bench as well as jurisdictional High Court, we allow assessee s claim of house property income in respect of sub-leasing of office premises. 45. The last issue in ground no.9 relates to levy of interest under sec .....

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of interest by dismissing the ground raised by the assessee. 48. In the result, assessee s appeal is partly allowed. We now take up Revennue s appeal in ITA no.3242/Mum./2008, for the assessment year 2003-04. The Revenue has raised following grounds in its appeal:- "1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in excluding 'Syngene International Pvt. Ltd.' as a comparable for determining the Arms Length Price of the International transac .....

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irst ground relates to exclusion of Syngene International Pvt. Ltd., as a comparable by the learned Commissioner (Appeals) as far as international transaction relating to CSMM support services. In course of proceedings before the Transfer Pricing Officer, though the assessee objected to selection of aforesaid company as a comparable on the ground that it is a wholly owned subsidiary of Biocon India Ltd. and as per the disclosure made by the company itself, it has related party transaction but th .....

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contention, excluded Syngin International Pvt. Ltd. from the list of comparable. 50. The learned Departmental Representative submitted before us, the related party transaction of the company is not to the extent that it cannot be considered as a comparable. In this context, he referred to the annual report of the company placed in assessee s paper book and submitted that the related party transaction has not exceeded 25%. He further submitted that the Transfer Pricing Officer has not applied re .....

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ort no segmental analysis has been done He, therefore, submitted that in the absence of segmental analysis, it cannot be considered as a comparable. In this context, he relied upon the decision of the Tribunal, Mumbai Bench, in Evonik Degussa India Pvt. Ltd. v/s ACIT, ITA no.7653/Mum./2011, order dated 21st November 2012. 52. Having considered the submissions of the parties, we are of the view that Syngene International Pvt. Ltd. has been correctly treated as uncomparable to the assessee. As cou .....

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of the Tribunal in Evonik Degussa India Pvt. Ltd. (supra). In the aforesaid view of the matter, we uphold the order of the first appellate authority on the issue by dismissing ground no.1, raised by the Department. 53. In ground no.2, the Revenue has challenged the decision of the learned Commissioner (Appeals) in allowing market research expenses of ₹ 54.14 lakh as business expenses. 54. Briefly stated the facts are, during the assessment proceedings, the Assessing Officer, while examinin .....

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