9911796707
TMI Blog1985 (7) TMI 141X X X X Extracts X X X X X X X X Extracts X X X X ..... . A sum of Rs. 60,891 was disallowed by the ITO out of advertisement expenses out of total expenses of Rs. 1,87,593. The Commissioner (Appeals) while dealing with the issue in the assessee's first appeal before him, deleted the same observing that the company had started manufacturing a new commodity and, therefore, sampling and advertisement was necessary. When the matter at the instance of the revenue came before the Tribunal, the Tribunal restored it back to the file of the Commissioner (Appeals) observing that the decision of the Commissioner (Appeals) was on a wrong premise. However, the Tribunal sent the matter back to be readjudicated on merit. The Commissioner (Appeals) again considered the submissions of those of the assessee and f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r and again, he submitted, it has been claimed and allowed in the past, and future all through. 4. It is trite law by now that every assessment year is independent. May be that the revenue in the past did not bother to look into the assessee's claim due to insignificance of its percentage over the sales. Even during the year under consideration, it was 0.25 per cent while earlier it was only 0.09 per cent and 0.10 per cent in the immediately two preceding years. But once the revenue has gone into investigation of a particular item, its allowance is to be adjudicated on merit. Regarding sampling, there has to be some uncodified code. We could appreciate the submission of the learned counsel for the assessee that in Congress Session and spor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... free sampling given to Shri A.P. Singh, Assistant 715.65 Accounts Officer. October 1975 To C/o free sampling given to Shri Harmohinder Singh 231.25 and Shri Harcharan Singh. To C/o free sampling given to Shri A.P. Singh, Assistant 1,194.00 Accounts Officer. To amount of free sampling given to M/s Sisco. 1,300.95 To C/o free sampling given to Shri Sharma. 105.60 To amount of free sampling given to Shri Khanna and 977.90 Shri Kishan Kumar. November 1975 To C/o free sampling given to Shri Harcharan Singh. 278.60 To C/o free sampling given to Shri Kulwant Singh and 829.80 Shri Jagdish Kumar. To amount of free sampling given to Shri S. Khanna and 826.05 Shri R.S. Dogra. December 1975 To C/o free sampling given to Shri H.R. Seth and 884.10 Shri ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing given to M/s Walia Soft Drinks. 469.00 To amount of free sampling given to Shri Yajjan Singh 2,514.36 and Shri Jaswant Singh. To C/o free sampling given to Shri Darshan Singh and 276.12 Shri S.K. Seth. To C/o free sampling given to Shri Daulat Ram Khanna 1,051.86 and Shri Amar Singh on his daughter's marriage. To C/o free sampling given to Shri Atma Singh and 301.16 Shri Mohinder Singh. May 1976 To C/o free sampling given to Shri H.S. Dhillon on his 194.52 daughter's marriage. To C/o free sampling given to Miss Kangon Gupta. 1,263.30 To C/o free sampling given to Shri Kishan Singh. 2,475.30 To C/o free sampling given to M/s G.K. & Sons and 1,012.53 Kool Drinks Pta. To amount of free sampling given to Shri Mohinder Singh 2,515.68 on his ..... X X X X Extracts X X X X X X X X Extracts X X X X
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