2018 (1) TMI 1242

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....Shankar, Advs ORDER The question of law urged in this appeal under Section 260A of the Income Tax Act, 1961 ('the Act') by the Revenue is with respect to the correctness of the Income Tax Appellate Tribunal's (ITAT) decision that Rs. 9,37,29,000/-, which had been disallowed from the sales promotion expenditures by the Assessing Officer (AO), fell in the revenue stream rather than the capital....

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.... Jute Co. Ltd. Vs. Commissioner of Income Tax, (1980) 124 ITR 1 (SC) to say that the ratio of that judgment fairly implies to lead to conclusion that the high degree of expenditure in this case and disallowed by the AO, actually meant creation of an asset or resulted in an enduring capital advantage to the assessee. This Court is of the opinion that the concurrent findings on the question urged....