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TMI Blog2016 (9) TMI 1267X X X X Extracts X X X X X X X X Extracts X X X X ..... any manner related to the assessee company. The only purpose of the assessee company to sponsor the foreign trip of the doctors was for the purpose of promotion and sale of the products of the assessee company. It may be unethical practice for the doctors to accept such type of incentives, however, so far as the assessee is concerned, sponsorship was purely on account of business angle of the assessee company. - Decided in favour of assessee. - ITA No. 4791/MUM/2014 - - - Dated:- 9-9-2016 - G. S. Pannu (Accountant Member) And Ram Lal Negi (Judicial Member) For the Appellant : B. V. Jhaveri For the Respondent : A. Ramchandran ORDER Ram Lal Negi (Judicial Member) This appeal has been preferred by the appellant/asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f doctors has overlooked the fact of commercial expediency and business necessity of such expenditure and that the expenditure was incurred by the appellant wholly and exclusively for the purpose of the business. 4. The Ld. Authorised Representative (AR) at the outset pointed out that the issue involved in the present appeal has been decided by the Mumbai Bench of ITAT in favour of the assessee in assessee s own case in ITA No. 847/Mum/2012 for the A.Y. 2008-09 and cross appeal, ITA No. 388/Mum/2012 filed by the department. 5. On the other hand the Ld. Departmental Representative (DR) relying on the concurrent findings of the authorities below, submitted that since the expenditure was not incurred wholly and exclusively for the purpos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e us that the detailed reply was submitted to the lower authorities explaining that the assessee sponsors various events and seminars at various places to encourage product awareness programs. As a part of sales promotion and product awareness program, the foreign tours of the selected doctors were sponsored and this was combined with the product awareness campaign by the assessee. This was also done to create good relationship with the doctors. The assessee had also furnished a list of doctors who had been sponsored along with the visit photographs. The lower authorities had not doubted the incurring of expenses but were of the view that the said expenditure was not directly relating to the business activity of the assessee. In our view, t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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