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    <title>2025 (1) TMI 565 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai ruled in favor of a pharmaceutical manufacturer regarding marketing expenses disallowed as capital expenditure. The assessee paid NHPL for market development activities including staff recruitment, sales personnel salaries, and management services. The court held these expenses were revenue in nature as they related to product sales activities. The AO had inconsistently treated similar expenses, allowing them in reassessment proceedings for AYs 2019-20 and 2020-21 but disallowing them for AYs 2021-22 and 2022-23. ITAT directed deletion of disallowances, emphasizing consistency principle and confirming the revenue nature of marketing expenses.</description>
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