2006 (2) TMI 87

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..... the Income-tax Act, 1961 against the order of the Income-tax Appellate Tribunal in I.T.A. No. 2031 (Mds) of 1996 dated September 30, 2003, raising the following substantial question of law: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in holding that crop development expenditure of Rs. 20,36,157 and project launching expenses of Rs. 16,4 .....

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..... ccounts. However, the assessee claimed it as revenue in the statement of computation of total income and also further disallowed the expenses incurred amounting to Rs. 16,41,125 towards advertisement in respect of soya products and sales promotional expenses. Against the order of assessment, an appeal to the Commissioner of Income-tax (Appeals) was filed by the assessee. The Commissioner of Income .....

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..... ture and that the participation of the farmers was ensured in developing the said crop. The assessee had incurred expenditure in making publicity through visual media as well as print media, distribution of seeds and fertilizers, for maintaining demonstrative plots, for conducting seminars for the local population, prize distribution to farmers, etc. These expenses were necessary and usually expen .....

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..... e these expenses were also in the nature of business expenditure entitled for deduction in computing the assessee's income. The other contention pointed out by learned counsel was that these items were accounted by the assessee as capital items, but were treated as revenue items, only for the purpose of income-tax. The assessee might have treated those two amounts as capital expenditure in its re .....

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..... ax Act. So, we are of the view that the crop development expenses and new project launching expenses were rightly held by the authorities as revenue expenditure. In the foregoing conclusions, we find no error or infirmity in the order of the Tribunal. Hence, no substantial question of law arises for consideration of this court. Accordingly, the above tax case is dismissed. No costs.
Case laws .....

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