Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

9. That the assessing officer erred on facts and in law in disallowing under section 40(a)(ia) expenditure of Rs. 64,08,000 incurred on account of provision towards advertisement and publicity expenses created at the end of year, on the ground that the assessee failed to deduct tax at source therefrom under section 194C