Assessee furnished confirmation from NHPL and other corroborative evidences to demonstrate that market development expenses were incurred not only for sale of product but also to expand its market presence. On perusal of the said confirmation and evidences, it was found that expenses incurred primarily involve expenditure related to sale of product, such as, staff recruitment charges, salary and expenses of territory sales executives, salary and expenses of sales personnel manager, etc. Personnel engaged in sale of product of assessee belonged to NHPL. It could not be therefore, denied that market development expenses were towards sale of product, hence, revenue in nature. Further, AO reopened assessments for assessment years 2019- 20 and 2020-21 to disallow market development expenses, however, after considering the objections and submissions of assessee, the AO accepted assessee’s claim of market development expenses. Therefore, principle of consistency would be maintained by following the position taken in reassessment proceedings for assessment years 2019-20 and 2020-21. Hence, market development expenses, being in the nature of revenue expenses, were allowable. [AY.  2021-22, 2022 -23 ]