Pr. Commissioner of Income-tax-6 v. Matrix Cellular International Service Pvt. Ltd
|Pr. Commissioner of Income-tax-6
|Matrix Cellular International Service Pvt. Ltd.
|Date of Order
|advertisement expenditure • revenue expenditure
|UPON hearing the counsel the Court made the following ORDER Delay condoned. The learned Additional Solicitor General has addressed submissions to challenge the correctness of the Signature Not Verified findings of the High Court on the issue of advertisement Digitally signed by SANJAY KUMAR Date: 2019.04.27 11:09:29 IST Reason: expenses. The High Court has adverted to two circumstances, while upholding the decision of the 2 Tribunal: firstly, for the previous Assessment Year 2008- 2009, the same view of the Tribunal regarding the allowability of advertisement expenditure as revenue expenditure has not been challenged; secondly, the High Court has adverted to its own decision in the case of CIT v. Pepsico India Holdings India Ltd.1 The learned Additional Solicitor General attempted to distinguish the decision on the ground that it dealt with advertisements on hoardings. We find no substance in that distinction In our considered view, the view which has been taken by the Tribunal and, sustained by the High Court, does not call for interference under Article 136 of the Constitution. The Special Leave Petition is accordingly dismissed.