Advertising expenditure classification as revenue (not capital) - held deductible; capital treatment set aside on appeal

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....Whether advertising expenditure is revenue or capital: applying statutory principles and binding precedent, the court rejected estoppel against the statute and held that characterization in books does not override tax law; relying on Supreme Court authority and Gujarat HC precedent, such advertisement outlays are not capitalizable but are revenue expenditures deductible under the Act. Consequence: the assessment treating the expenditure as capital was set aside and the appeal allowing deduction was allowed. - HC....