DCIT, CC-31, NEW DELHI vs. PERNOD RICARD INDIA PVT. LTD., NEW DELHI
In the result, the appeals filed by the Revenue are dismissed and the appeals filed by the assessee are partly allowed for statistical purposes
ITA 2601/DEL/2019[2014-15]Status: DisposedITAT Delhi15 May 2020AY 2014-15
Bench: Shri R.K. Panda & Ms Suchitra Kamble
For Appellant: Shri Deepak Chopra, AdvocateFor Respondent: H.K. Choudhary, CIT, DR
Section 92C
…partly allowed the ground raised by the assessee by directing the AO to allow the actual transit breakage for the impugned assessment year in the light of the decision of the Hon’ble Delhi High Court in the case of Seagram Manufacturing Pvt. Ltd., reported in 378 ITR 581 which has subsequently been affirmed by the Hon’ble Apex Court vide CC No.12104 of 2016, order dated 11th July, 2017. 10. So far as the disallowance of Rs.50,38,72,290/- being 20% of brand building expenses of Rs.251,93,611,449/- is concerned, the ld.CIT(A), following the order of the Tribunal in assessee’s own case for A.Y. 2004-05 and 2005-06,…