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TMI Blog2018 (3) TMI 464X X X X Extracts X X X X X X X X Extracts X X X X ..... rd Ld. Departmental Representative and proceeded to dispose the appeal on merit after considering the written submission filed by the assessee. 3. Ms. S. Vijayaprabha, the Ld. Departmental Representative submitted that the only issue arises for consideration is disallowance of advertisement expenditure to the extent of Rs. 86,71,507/- incurred on the project known as "Atlantis". According to the Ld. D.R., the assessee claimed advertisement expenditure in respect of project "Atlantis". However, no income was offered from that project. Therefore, according to the Ld. D.R., the Assessing Officer found that the expenditure relating to the project "Atlantis" has to be capitalized. The Ld. D.R. further submitted that the assessee segregated the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ver basis. Advertisements given are mostly in general for all the projects in progress. Only for a reference, an analysis is made to apprise themselves of an approximate cost of the project. The basis of the accounting also is to claim the advertisement whenever it is incurred and especially whenever launching is done, a major amount is spent and booking made and small advances are received. The income from the project usually accrues only after 3 to 4 years when the project is completed and registered. This basis has been followed all along the past and even in this year, the same basis is adopted. In income-tax parlance, a basis adopted should be followed and it is not permissible to change the basis. Normally, real estate advertiseme ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the advertisement has to be continued further. Under the circumstance, advertisement is to be done irrespective of the generation of income from a particular project. Of late, due to the slackness in the real estate business, people are carrying inventory without demand which needs more and more advertisements without proper sales." 6. We have heard Ld. Departmental Representative and perused the written submission filed by the assessee and the material available on record. The only issue arises for consideration is disallowance of advertisement expenditure to the extent of Rs. 86,71,507/-. The main contention of the Revenue is that the assessee has not offered any income in respect of the project called "Atlantis", therefore, the expendit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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