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ITAT dismissed the assessee's appeal, rejecting the claim for full expenditure deduction related to exhibition expenses. The tribunal determined that while brand promotion was involved, the entire expenditure cannot be claimed due to the separate entity principle. The court reasonably allowed 25% of expenses, which was more favorable than the assessee's 10% profit share, emphasizing the subjective nature of determining indirect benefits based on specific case facts and commercial context.
ITAT dismissed the assessee's appeal, rejecting the claim for full expenditure deduction related to exhibition expenses. The tribunal determined that while brand promotion was involved, the entire expenditure cannot be claimed due to the separate entity principle. The court reasonably allowed 25% of expenses, which was more favorable than the assessee's 10% profit share, emphasizing the subjective nature of determining indirect benefits based on specific case facts and commercial context.
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