DCIT, NEW DELHI vs. M/S. STUDY OVERSEAS GLOBAL (P) LTD., NEW DELHI

ORDER

PER H.S. SIDHU, JM

in the revenue’s appeal read as under:-

1. On the facts and circumstances of the case, the Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 1,21,89,908/- made by the AO on account of Management Fee.

2. On the facts and circumstances of the case, the ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 12,74,019/- which was disallowed by the AO treating the advertisement expense of Rs. 25,48,038/- as capital expenditure after allowing depreciation @ 50%.

3. The appellant craves to amend modify, alter, add or forego any ground of appeal at any time before or during the hearing of this appeal.

2. At the time of hearing, Ld. Counsel for the assessee has drawn our attention towards a letter dated 20.10.2018 filed by her which is on record and submitted that the tax effect in respect of this appeal is lower than the monetary limit for tax effect. She also submitted that the additions raised in the grounds of appeal are wrongly mentioned by the Department. However, the additions and the tax effect involved in the present appeal is as under:-

S.No. Point of addition Amount of addition 1. Management fee paid to SOIPL 14,56,317/- 2. Advertisement expenditure 12,74,019/- 3. Total addition / disallowance 27,30,336/- 4. Rate of tax (including cess 3%) 30.9% Tax effect 8,43,674/-