ADDL CIT RG 8(2), MUMBAI vs. PROCTOR & GAMBLE HYGINENE & HEALTH CARE LTD, MUMBAI

ITA 3566/MUM/2012Status: DisposedITAT Mumbai12 December 2023AY 2007-0835 pages
AI SummaryAllowed

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?

Section 80IB

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Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SHRI ABY T VARKEY & SHRI AMARJIT SINGH

For Appellant: Ms. Sukanya
Hearing: 19.10.2023Pronounced: 12.12.2023

Per Amarjit Singh (AM): All these cross appeals are filed by the assessee and revenue for assessment year 2006-07 to 2008-0

The order continues below.

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