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TMI Blog2019 (3) TMI 313X X X X Extracts X X X X X X X X Extracts X X X X ..... AO was far more reasonable in disallowing only 10% of the said expenditure. Accordingly, ground raised by the assessee on this score is dismissed. Disallowance being exhibition expenses incurred on the ground that these did not pertain to impugned Assessment Year - allowable business expenditure - HELD THAT:- When the payment of participation for exhibition purpose has been made in this year then ostensibly such a payment is revenue in nature incurred for the purpose of business, then the same has to be allowed in the year in which it has been incurred, because for participating in the exhibition it was essential that payment has to be made in advance even if such an exhibition of international trade fair was to be held in the next Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs.6,066/- Ring Rs.22,170/- Gold chain Rs.3,51,167/- Gold chain/Diamond Pandal Rs.3,06,622/- Gold chain/Diamond Pandal Rs.6,616/- Gold chain Rs.1,18,700/- Gold chain/Diamond Pandal Rs.12,273/- Gold cum Diamond Ring Rs.11,716/- Gold chain Rs.2,16,181/- Gold chain/Diamond Pandal Rs.10,11,032/- Gold cum Diamond Ring ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sallowance made by the Assessing Officer is very reasonable which should not be tinkered with. 7. After hearing both the parties and on perusal of the impugned order and material referred to before us, we find that though assessee has given the list of the item distributed to various customers, however, nowhere it is borne out from the records as to whether distribution of gold and diamond ring and chains were part of the sales promotion activities. Neither any pamphlet of any scheme of sales promotion has been filed nor has any business purpose been shown specifically when the items distributed are more of a personalized in nature. In absence of any proper evidence to demonstrate that these items were actually used for business purpose, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e international trade fair for the automobile industry. The payment made by the assessee is not in dispute which is evident from the letter written by M/s. Messee Franfurt Trade Fairs (P) Ltd., the copy of which is appearing at page 2 of the paper book and also the copy of invoice and receipt which are appearing at pages 73 and 74 of the paper book. When the payment of participation for exhibition purpose has been made in this year then ostensibly such a payment is revenue in nature incurred for the purpose of business, then the same has to be allowed in the year in which it has been incurred, because for participating in the exhibition it was essential that payment has to be made in advance even if such an exhibition of international trade ..... X X X X Extracts X X X X X X X X Extracts X X X X
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