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TMI Blog2018 (3) TMI 464X X X X Extracts X X X X X X X X Extracts X X X X ..... t be related to a particular project which is undertaken by the assessee in a particular year. At the best, it can be relatable to the year in which the advertisement was made. Merely because the assessee segregated the cost of expenditure in relation to a particular project and later stage claimed as general advertisement expenditure that may not alter the character of the advertisement expenditure incurred by the assessee. As long as the expenditure on the advertisement made during the year under consideration is not in dispute, it cannot be disallowed by the Assessing Officer on the ground that no income was disclosed in respect of a particular project known as “Atlantis”. Hence, this Tribunal is of the considered opinion that the CIT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aimed as advertisement expenditure. Therefore, according to the Ld. D.R., the segregation made in the Profit Loss account cannot be ignored, hence, it cannot be allowed under Section 37 of the Act as revenue expenditure. 4. Referring to the order of the CIT(Appeals), the Ld. D.R. submitted that the CIT(Appeals) found that the assessee claimed composite expenditure with regard to advertisements and followed consistent method of accounting. According to the Ld. D.R., only revenue expenditure can be claimed as allowable deduction. Since the income was not offered in respect of the project Atlantis , the expenditure relating to that project can be claimed only in the subsequent year. According to the Ld. D.R., the segregation of expenditu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... launching is done, a big advertisement of the new project contains fuller design and a Cad design of the eventual building. The name of the Company, the name of the project, the brand name and the names of other projects completed and in progress are displayed to project the image and goodwill of the organization. The popularity and the reliance of the trade name count which generate good turnover and demand in the business. When the launching is done, no income at the time of launching or for one or two years will arise till almost the project is completed when the registration is done. Amounts received from day one at the time of launching till the registration is completed, the income does not arise. This practice is in the line of our ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year under consideration. According to the Ld. D.R., at the best, it can be allowed in the subsequent year when the assessee offers the income. It is not in dispute that the assessee is in the business of real estate development and civil construction. In the course of its business activity, the assessee developed several projects. One of the projects is known as Atlantis . The assessee made several advertisements to promote its business. It is also not in dispute that the assessee developed several projects. One among them is known as Atlantis . When the assessee made advertisements, as claimed by the assessee in its written submission, it displayed the name of the concern, name of the projects, brand name, etc. Such advertisements will ..... X X X X Extracts X X X X X X X X Extracts X X X X
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