TMI Blog2008 (8) TMI 138X X X X Extracts X X X X X X X X Extracts X X X X ..... ntire expenditure on advertising to be of a revenue nature – whether unutilized DEPB credit is allowable, whether professional fee for human resource engineering to be amortized are question of law, so appeal is admitted - 1581 of 2007 and 173 of 2008 - - - Dated:- 18-8-2008 - BADAR DURREZ AHMED and RAJIV SHAKDHER JJ. Ms. Premlata Bansal for the appellant. P. N. Monga and Manu Monga for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... file on December 5, 2007. The delay in filing the appeal has occurred because these circumstances and not because of any intentional or unavoidable delay on the part of the appellant. 2. After hearing the counsel for the parties, we feel that this is a case in the delay is fully explained and ought to be condoned. The delay is condoned. This application is allowed and it stands disposed of acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t there was a direct nexus between the advertising expenditure and the business of the assessee and that the assessee had to incur such expenditure to meet the competition in the Indian market for selling its products in India. A finding was returned that unless the assessee made its products known to the market, its business would suffer. Consequently, the Tribunal held the entire expenditure on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7] 294 ITR 451. This court has decided these questions against the revenue and in favour of the assessee. So, on this issue also, no substantial questions of law arise. 6. However, we feel that the following two substantial questions of law do arise for our consideration : "1. Whether the Tribunal was correct in law in deleting the addition of Rs. 25,29,431 made by the Assessing Officer by a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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