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TMI Blog2014 (6) TMI 502X X X X Extracts X X X X X X X X Extracts X X X X ..... the order of the CIT(A) - the allocation as done by the AO was not required to be done in respect of expenses relating to rent, power, telephone and depreciation – Decided against Revenue. - I.T.A. No.1695/Mum/2013 - - - Dated:- 29-5-2014 - Shri I. P. Bansal, (JM) And N. K. Billaiya (AM),JJ. For the Appellant : Shri Jitendra Yadav For the Respondent : Shri Prakash Kotadia and Deepak Murarka ORDER Per I. P. Bansal, JM: This appeal is filed by the Revenue. It is directed against the order passed by ld. CIT(A) dated 5.12.2012 for the assessment year 2009-10. 2. Grounds of appeal taken by the Revenue read as under : 1. On the facts and in the circumstances of the case and in law, the ld CIT(A) erred in dele ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... P3 LLC is a sum of Rs.49,98,094/- towards marketing, public relations and publicity and branding services. 4. For the purpose of cost plus mark-up15% for the services rendered to P3 LLC, the assessee identified direct expenses attributable to provision of such services and in case of common expenses, the same have been allocated on the basis of sales. During the course of assessment proceedings, the AO required the assessee to submit segment wise profit and loss account giving particulars of export business and domestic business segment. From the details, the AO came to know that assessee did not allocate any expenses towards rent, power, telephone and communication expenses and depreciation. While computing the cost for the purpose of m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e aforementioned addition has been deleted by the ld. CIT(A) on the basis of the submission of the assessee that it had outsourced marketing public relation, publicity and trading work by appointing third party agencies M/s MVP Design Protocol Pvt Ltd. and Text Hundred India (P) Ltd. Therefore, the expenses in the nature of rent, power, telephone, communication and depreciation had nothing to do with the cost incurred by the assessee in respect of export segment. It was submitted that M/s MVP Design Protocol Pvt Ltd was paid Rs.19,80,000/- to provide branding, design and marketing related services. Text Hundred India (P) Ltd was paid Rs.15,21,450/- to provide public relation and marketing selling services. Since these services were outsourc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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