TMI Blog2017 (11) TMI 1312X X X X Extracts X X X X X X X X Extracts X X X X ..... stantial question of law warranting interference with the impugned order of the ITAT. ITAT has followed the earlier order in the case of Samsung India Electronics Pvt. Ltd. v. Department of Income Tax [2013 (4) TMI 872 - ITAT DELHI] was followed. Treatment of advertisement and sales promotion expenses on basis of "brand promotion" or "capital nature" - expenses on computer software and on recru ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Act, 1961 ( Act ), by the Revenue is against the order dated 30th September, 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 930/Del/2010 for the Assessment Year ( AY ) 2002-03. 4. One of the questions of law sought to be raised by the Revenue stems from the order of the Transfer Pricing Officer ( TPO ). Disagreeing with the said order, the ITAT directed that the entire rei ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d to do so. The ITAT's view in the above matter is plausible. It does not give rise to any substantial question of law warranting interference with the impugned order of the ITAT. 6. The other issues raised by the Revenue concern the treatment of the advertisement and sales promotion expenses both on brand promotion and capital nature of the advertisements and sales promotion expenses; expe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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