1984 (2) TMI 176

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....f the outlay represented articles of value of Rs. 50 or below, the ITO was of the view that the value of such articles could be allowed as a deduction. The balance of Rs. 32,465 was sought to be disallowed because they represented articles of value of more than Rs. 50 per article. The assessee claimed that these were nothing more than discounts in kind inasmuch as the assessee had a sales promotion scheme under which the assessee gave away watches and time pieces depending upon the offtake. It is on this basis the articles were given. Details of the scheme and the details of the articles given away with the names of the parties were filed. The ITO was of the view that the expenditure on these articles was clearly in the nature of advertisem....

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.... Vijayawada [IT Appeal No. 871 (Hyd.) of 1982] wherein the amount in excess of Rs. 50 was also allowed by this Tribunal following an earlier decision in IT Appeal Nos. 1027 and 1029 (Hyd.) of 1982, dated 29-4-1983. In the latter order (to which one of us was a party), the question as to what constitutes advertisement was discussed in the following words : " 'Advertisement' according to Concise Oxford Dictionary is 'public announcement (esp. in newspapers, or posters, by television, etc.) ; advertising....... Advertise' has been similarly defined to mean 'generally or publicly known ; (esp.) describe (goods), publicity with a view to increasing sales ; notify... '. Meaning assigned in other dictionaries are not different. Though dictionar....