TMI Blog2020 (5) TMI 335X X X X Extracts X X X X X X X X Extracts X X X X ..... memory is very short and, therefore, the companies have to incur advertisement expenditure year after year to keep products fresh in the minds of the public - such expenditure cannot partake the character of giving any enduring benefit. AO has grossly erred in treating such expenditure as intangible asset and on facts of the case, the findings of the Id. CIT(A) needs no interference. - Decided in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... future benefits and enduring in nature. The Assessing Officer has observed that by incurring the said expenditure, the assessee is building a brand image of the parent company and capital in nature. The A.O. denied the claim of assessee treating the same as revenue expenditure and disallowed under section 37(1) of the I.T. Act, 1961. The Ld. CIT(A), after considering the submissions of both th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 15. We have heard the rival submissions and have given thoughtful consideration to the orders of the authorities below qua the issue. It would be pertinent to mention here that during the course of assessment proceedings, the case was referred to the TPO and the TPO framed order u/s 92CA(3) of the Act on 09.01.2014 and no adverse inference was drawn in respect of I.T. notification by the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is covered in favour of the assessee by the Order of the Tribunal above. 5. Considering the facts of the case in the light of the Order of the Tribunal Dated 11.04.2019 (supra), we are of the view that the issue is covered in favour of the assessee by this Order. Following the same, we dismiss the appeal of the Revenue. 6. In the result, appeal of Revenue dismissed. Order pronounced in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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