AO held that expenditures were incurred by the assessee after issuance of certificate of Censor Board and hence, he disallowed the assessee’s claim holding that such expenditure was not allowable deduction in terms of rule 9A and rule 9B.CIT(A) held that any expenditure which was not allowable under rule 9A could not be granted in terms of S.\u00a0 37(1) of the Act. Tribunal allowed the claim of the assessee. On appeal by the revenue the Court held that expenditure on cost of print and publicity were incurred after production and certification of film by Censor Board was received. Accordingly the said expenditure is not governed by Rule 9A hence allowable as revenue expenditure. Court also held that even if the Commissioner’s contention that the expenditure would fall within rule 9A has to be accepted, there would be no implication of the assessee’s tax liability, since in the instant case, the feature film was exhibited long before the completion of 90 days period before the end of financial year. Even as per rule 9A, such expenditure was otherwise allowable. Be that as it may, on interpretation of the relevant statutory provisions, the Tribunal is absolutely correct. (AY. 2006-07, 2009-10)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 37(1) : Business expenditure\u2013Cost of print and publicity\u2013cost of production- Feature films -Expenditure were incurred after production and certification of film by Censor Board was received \u2013 Not governed by Rule 9A- Allowable as revenue expenditure. [R. 9A 9B]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-6256","post","type-post","status-publish","format-standard","hentry","category-digest"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-1CU","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/6256","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=6256"}],"version-history":[{"count":0,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/6256\/revisions"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=6256"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=6256"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=6256"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}