9911796707
TMI Blog1992 (4) TMI 104X X X X Extracts X X X X X X X X Extracts X X X X ..... incurred for demonstration of Yamaha Generators, useful for country boats, for which the assessee had taken dealership. In the accounts of the previous year ended 31st March, 1992, the assessee had shown a sum of Rs. 3,85,520 as sales promotion expenses and Rs. 1,43,539 as generator demonstration expenses. It is now stated that out of the sum of Rs. 3,85,520 a sum of Rs. 1,47,556 represented amou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o had to know how to operate the machine since it was now in the filed. It was submitted that this could not be considered as an ostentatious expenditure for the purpose of disallowance. On the other hand, the Revenue supported the order of the authorities below by claiming that even a demonstration of the product invites customers and should be regarded as publicity attracting the provisions of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of a product to prospective users could not be regarded as such wasteful expenditure as to fall within the scope of the section. We, therefore, accept the claim of the assessee and direct the authorities below to exclude these two sums of Rs. 1,47,556 and Rs. 143,539 from the scope of the application of s. 37(3A). 4. The other common point in the appeals of the assessee and the Revenue relates ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r ground in the appeal of the Revenue relates to the claim of the assessee for investment allowance under s. 32A(2). The objection was that the production of processed sea foods cannot be regarded as a manufacturing activity. But it is pointed out by the assessee that for the earlier asst. yrs. 1981-82 and 1982-83 in the assessee s own case, the Tribunal had held by order dt. 6th March, 1987 in IT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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