CIT Vs. SONY INDIA PVT. LTD

JUDGEMENT

(1.) BY order dated 20th March, 2012, we had admitted the present appeal on the following substantial question of law-

(2.) HOWEVER , we did not admit the appeal of the Revenue on the question whether 10% of the sales promotion and the advertisement expenditure was incurred to give advantage and benefit to the principal/parent company and, therefore, was not allowable as a deduction.

(3.) OUR order dated 20th March, 2012, does not refer to these three/two issues and, therefore, we had issued notice to the respondents-assessee. It appears that these issues were not specifically argued but this is not so stated or recorded in the said order. In these circumstances, we have heard the learned counsel for the applicant on the aforesaid three/two issues.