1999 (9) TMI 32

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....the Revenue's dogged persistence in a matter which in the least warrants it. The Central Board of Direct Taxes itself had in a circular inter alia, clarified the scope of the terms "publicity" and "sales promotion" for the purposes of section 37(3A), inter alia, in the following terms: "As the terms 'publicity' and 'sales promotion' have a wide amplitude, expenditure incurred by taxpayers on fash....

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....pproach this court against the order of the Tribunal, which is in conformity with what the Central Board of Direct Taxes itself had stated. That there is a difference between sales and sales promotion is self-evident. All expenses relating to sales incurred in the normal course for effecting such sales must necessarily to be allowed as expenditure connected with the business, under section 37 of ....

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.... sales of the product. Commission paid to the persons, who effect the actual sale, at a percentage of the value of the product and salary paid to employees such as marketing officers and sales personnel and persons manning the sales offices are obviously expenditure incurred for effecting normal sales, and do not amount to the special sales promotion expenses. By and large sales promotion expenses....