2013 (11) TMI 129

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....e Assessing Officer on account of advertisement expenses.   2. Whether the learned Commissioner of Income-tax (Appeals) was correct on facts and circumstances of the case and in law in deleting the disallowance of Rs. 1,57,665 made by the Assessing Officer on account of depreciation on printers and scanner. 3. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of hearing." Apropos deletion of Rs. 8,76,435 In this case it was observed by the Assessing Officer that the assessee has claimed an amount of Rs. 10,95,543 being advertisement and marketing expenses as revenue expenditure. The Assessing Officer opined that the assessee has incurred this huge expenditure for launching its bra....

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....nd perused the records. We find that the case law relied upon by the Assessing Officer in the case of Madras Industrial Investment Corporation Ltd. v. CIT [1997] 225 ITR 802 (SC) is not applicable on the facts of the present case. In the aforesaid case the said Corporation issued debentures in December, 1966 at a discount. The total discount on the issue of Rs. 1.5 crores amounted to Rs. 3,00,000 for the assessment year 1968-69. The company wrote off Rs. 12,500 out of the total discount of Rs. 3,00,000 being the proportionate amount of discount for the period of six months ending June 30, 1967 taking into account the period of 12 years which was a period of redemption and discount for Rs. 3,00,000 over the period of 12 years. In these circu....