2012 (3) TMI 363

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.... Kumar, SDR For the Respondent: Shri S. Murugappan, Advocate JUDGEMENT               Per: Mathew John The respondents in this case were engaged in the manufacture of Cinematographic Positive films, Photographic Films and Photographic Paper. They manufactured the goods and sold it at a price to M/s. Asian Photographic....

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....e argument of Revenue and he set aside the demand. Aggrieved by the order of Commissioner (Appeals), Revenue has filed this appeal. 3. Learned authorized representative for the Revenue submits that M/s. APFP was the sole selling agent of the respondents. He also points out that two Directors were common for the manufacturing company as well as the sole selling agent and, therefore, the expendit....

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....uments from both sides and we find merit in the argument of the respondents inasmuch as there is nothing unusual about the sole selling agent incurring advertising expenditure to promote his business. Such advertisement expenses cannot form part of the assessable value of the goods manufactured by the respondents. In the facts of the case, the sole selling agent is incurring such expenditure from ....