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TMI Blog2010 (11) TMI 674X X X X Extracts X X X X X X X X Extracts X X X X ..... he transaction to 'works' contract, so as to attract the provisions of S.194C of the Act - This issue is covered by the decision of the Delhi High Court in the case of CIT V/s. Dabur India Ltd. [2005 -TMI - 9609 - DELHI High Court] - Thus, the grounds of the Revenue in appeal are rejected - Decided in favour of assessee. - ITA No. 428/Hyd/2010 - - - Dated:- 26-11-2010 - G.C. Gupta, Chandra P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ute involved in this appeal relates to disallowance of advertisement expenditure of Rs.2,91,20,349 made by the Assessing Officer, invoking the provisions of S.40(a)(ia) of the Act, on account of non-deduction of tax at source by the assessee. 3. Facts of the case in brief are that the assessee is engaged in the business of manufacturing, bottling and sale of IMFL brands of UB Group in the manu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in terms of S.194C of the Act. On appeal, the CIT(A) deleted the said addition made by the Assessing Officer. Hence, Revenue is in appeal against the order of the CIT(A). 4. Learned Departmental Representative strongly relying on the order of the Assessing Officer, submitted that the CIT(A) was not justified in deleting the addition made by the Assessing Officer. On the other hand, the learne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dated 1.4.2005 has been entered by the assessee for marketing its products. In terms of clause (12) of the said agreement, M/s. Prayag Enterprises Limited was authorised to distribute all compliments, gift articles, cash incentives on behalf of the assessee to its retailers. Accordingly, M/s. Prayag Enterprises Ltd purchased pre-printed T-shirts from M/s. Sheshachalam Textiles Ltd. and supplied th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o covered by the decision of the Delhi High Court in the case of CIT V/s. Dabur India Ltd. (283 ITR 197), which in fact has been followed by the CIT(A) in the impugned order. In the circumstances, we find no infirmity in the order of the CIT(A), which is accordingly upheld and the grounds of the Revenue in this appeal are rejected. 6. In the result, appeal of the Revenue is dismissed. Orde ..... X X X X Extracts X X X X X X X X Extracts X X X X
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