Wholesale Buyers Bear Sales and Promotion Costs; Assessee Acts as Coordinating Agency, Not Sole Beneficiary of Premium.

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....The liability of sales and promotion expenses or advertisement lies with the wholesale buyers and not on the assessee and assessee merely acts as a coordinating/managing central agency. But such a managing and coordinating of advertisement does not implicate the assessee that it is the sole beneficiary or owner of the entire premium money generated - AT....