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"32. As it is not possible exactly to measure the benefit which has accrued and arisen to the parent company of the appellant and conversely the unnecessary expenditure incurred by the appellant company for the benefit of its parent company and because of the complete control of the affairs of the appellant by its parent company so much so that the officers of the appellant company are invariably the employees of the parent company of the appellant and have been deputed, deployed and assigned to run and control the appellant for the benefit of the parent company of the appellant; it is held that instead of a factor of 1.39%, the 50% of the expenditure incurred by the appellant on advertisement, marketing and promotion expenses is in respect of benefits accruing to the parent company of the appellant and therefore not necessary for the exigencies of the business of the appellant.