Section 92 of Income Tax Act,1961 not applicable to advertisement expenditure incurred by assessee, a wholly owned subsidiary of an American restaurant company in India

RELEVANT PARAGRAPH 8 We have heard the rival submissions and have gone through the material available on record and the judgments cited by Ld AR of the assessee. We find that in view of Master License Agreement dated 1.4.1996 and Service Agreement dated 1.4.1999, the assessee is running two types of businesses although both are connected with Mc Donald’s Corporation USA As per this agreement dated 1.1.1996 I.e. Master License Agreement, the assessee can operate restaurant system under Mc Donald’s System and the assessee can run it of its own or through franchises. In both these sit...