following the aforesaid
basis of apportionment of common head office and selling expenses from the
Assessment Year 1998-99 onwards.
The petitioner company also filed ... respective units, the allocation of common head office
and selling expenses to the units eligible for deduction under Section 80-1B
were also certified
selling expenses comprising of the following :-
"Salary & Wages, Advertisement expenses, Bank Charges, Business Promotion expenses, Travelling expenses, Commission to Selling Agents, Brokerage ... expenses" in respect of only the following items :-
"Salary & Wages, Advertisement expenses, Bank Charges, Business Promotion expenses, Travelling Expenses, Commission to Selling
expenses has been provided to us:-
Details of Total Amount Amount Administrative Marketing & Finance
Expenses Transferred to Debited to P&L Expenses Selling ... provisions of section 145A has rightly claimed the
proportionate salary expenses, administrative expenses and selling
expenses as revenue expenditure. The Ld. counsel has further contended
common for all the four years, is the disallowance of selling expenses claimed by the assessee as business expenditure. The assessee claimed that these amounts ... along with these appeals, we set out below the figures of selling expenses claimed under this head in all these eight years :
Assessment year
Amount
Insurance 0.26 0.26 0.26
Service charges to distributor 4.56 4.56 4.56
Selling expenses 5.77 5.77 5.77
Excise duty 9.44 8.30 8.58
------- -------- ------
21.21 27.85 25.39
- ------ -------- ------
Assessable ... claimed that the elements involved are octroi, insurance, freight and selling expenses and that these should be deducted from the sale price for arriving
sale
of paints, there are certain common head office and selling
expenses which are incurred by the assessee on account of both
the eligible ... adoption of rational basis for
apportionment of indirect expenses which include common head
office expenses and selling expenses and their quantification for
the purpose
giveaways, market study expenses, etc are required
to be excluded from the AMP expenses for computation of such ratios. These expenses
were incurred ... Selling expenses like dealer / staff incentive, gifts,
Festival giveaways , market study expenses etc (B) 7,84,96,501
Total Expenses including Selling Expenses
turnover of the Jammu (Water Based) factory ever total turnover.
Common Selling Expenses
The Company had already considered in the profit and loss account ... regard, the company has itself apportioned
common head office expenses and selling expenses to arrive at the amount deductible
u/s. 80lB
Insurance 0.26 0.26 0.26
Service charges to
distributor 4.56 4.56 4.56
Selling expenses 5.77 5.77 5.77
Excise duty 9.44 8.30 8.58
21.21 27.85 25.39
Assessable ... claimed that the elements involved are octroi, insurance, freight and selling expenses and that these should be deducted from the sale price for arriving
said expenses.
16. Before us, it was submitted by the ld. A.R that as the brokerage expenses
are finance/selling expenses, therefore, they have ... commission expenses, we find, that it is the claim of the assessee, that as the
said expenses are in the nature of selling expenses which
