2014 (3) TMI 953

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..... 1 : The learned Commissioner of Income-tax (Appeals) erred in confirming the addition made by the learned Assessing Officer for the claim of deduction towards market research expenses under section 37(1) of Rs. 14,03,000 by treating revenue expenditure as capital expenditure.               Ground No. 2 : Without prejudice to ground No. 1 the learned Commissioner of Income-tax (Appeals) erred in not giving deduction of 20 per cent. for net 5 years or depreciation on the capital expenditure. The appellant craves leave to add, amend, alter, modify or delete the above ground of appeal." 2. The brief facts of the case are that during the course of assessment proceedings ....

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....ommissioner of Income-tax (Appeals) observed that the assessee had indulged in market research through a consultant for bettering its business which would give enduring benefit to the assessee. The market research had come as a long-term benefit to the assessee by way of strategising its business so as to get greater turnovers in future years. He therefore held that the market research undertaken by the assessee had enduring benefit even though the issues in it were connected with the day-to-day business of the assessee. He therefore confirmed the addition so made by the Assessing Officer. Hence, aggrieved by the order, the assessee is in appeal before us. Our findings in respect of the matter are as under : Ground No. 1 3. Ground No.....