PROCTER & GAMBLE HYGIENE & HEALTH CARE LTD.,MUMBAI vs. ADDL.C.I.T. CIR. 8(2), MUMBAI
What did the Tribunal hold?
The Tribunal held that the expenditure on the production of advertisement films was revenue in nature, following previous decisions of the ITAT and the Bombay High Court. Consequently, the disallowance made by the Assessing Officer was deleted.
What were the facts?
The Assessing Officer treated advertisement expenses incurred on the production of television films and commercials as capital expenditure. The assessee contended these were revenue expenditures essential for business growth and did not create enduring benefits.
What were the issues?
Whether expenditure on production of television advertisement films is capital or revenue expenditure. Whether deduction under Section 80IB can be restricted for new product lines.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(10)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- Pandian Chemicals Ltd. v. CIT353 citing262 ITR 278 · 2003 · SC
- CIT v. Sterling Foods311 citing237 ITR 579 · 1999 · SC · Read judgment
- CIT v. Jeoffrey Manners & Co. Ltd.40 citing180 Taxmann 87 · 2009 · HC
- CIT v. Artex Manufacturing Co.36 citing227 ITR 260 · 1997 · SC · Read judgment
- Whittle Anderson Ltd. v. CIT36 citing217 ITR 250 · 1971 · HC
- 341 ITR 467 (Del) (3) ACIT v. S.K. Patel Family Trust34 citing38 SOT 208 · 2010 · ITAT
- Commissioner of Income Tax v. Electric Control Gear Manf. Co.26 citing227 ITR 278 · 1997 · SC
- CIT v. Patel International Film Ltd.14 citing102 ITR 219 · HC
- Punjab and Haryana in CIT v. Liberty Group Marketing Division9 citing173 Taxmann 439 · 2008 · HC
- 6 citing
Income Tax Appellate Tribunal, “J” BENCH, MUMBAI
Before: SHRI ABY T VARKEY & SHRI AMARJIT SINGH
Per Amarjit Singh (AM): All these cross appeals are filed by the assessee and revenue for assessment year 2006-07 to 2008-0
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More judgments on Section 80IB
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