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    <title>2022 (8) TMI 1621 - ITAT DELHI</title>
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    <description>An ad hoc disallowance of 50% of advertisement, publicity and sales promotion as capital expenditure on a brand-building theory cannot be sustained without concrete material showing creation of a capital asset or other factual basis for capital treatment; the expenditure was therefore treated as revenue in nature. TDS credit was to be verified and allowed accordingly, and the related claims for deduction under section 80G, dividend distribution tax credit, and interest under section 115P were to be processed through rectification under section 154 on the basis of details already furnished. The appeal was thus allowed in substance with consequential relief on credit and rectification matters.</description>
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      <title>2022 (8) TMI 1621 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=468362</link>
      <description>An ad hoc disallowance of 50% of advertisement, publicity and sales promotion as capital expenditure on a brand-building theory cannot be sustained without concrete material showing creation of a capital asset or other factual basis for capital treatment; the expenditure was therefore treated as revenue in nature. TDS credit was to be verified and allowed accordingly, and the related claims for deduction under section 80G, dividend distribution tax credit, and interest under section 115P were to be processed through rectification under section 154 on the basis of details already furnished. The appeal was thus allowed in substance with consequential relief on credit and rectification matters.</description>
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