No Section 14A Disallowance if investments are business expediency & strategic investments

DCIT Vs. Sri Rikhab Chand Jain (ITAT Kolkata) Payment for Purchase of Advertisement Materials would not attract TDS Under Section 194C of Income Tax Act, 1961 Expenses were claimed, by the assessee for poster, calendar, flex board, umbrella, air bag, hawker bags, cloth banner, pad, jute bags and pens etc. The AO had treated these payments as job work charges to various persons treated as contractors by the AO whereas the assessee claimed these expense as purchase price for procurement of various materials. We note that the assessee had claimed that the expenditure was not consideration for wor...