ITAT allowed the assessee's appeal. The Tribunal upheld the...

ITAT allowed the assessee's appeal. The Tribunal upheld the CIT(A)'s finding that payments of Rs.4,38,72,325 to an associate enterprise for marketing support were business-expedient and deductible under section 37, noting the protracted product approval and production cycle and subsequent procurement from a major OEM as linking expenditure to future commercial benefit. The Tribunal rejected disallowance of directors' remuneration, holding prior acceptance in other years and lack of requisite nexus to turnover did not warrant retrospective disallowance for unreasonableness. Expenditure on research and development was held allowable under section 35(2AB) from the certificate issuance date, not for the entire fiscal year.