JUDGMENT 1. Heard learned counsel for the parties. 2. This appeal is directed against the order of the Income-tax Appellate Tribunal, Jodhpur, dated October 10, 2001, passed jointly for the assessment years 1992-93 and 1993-94. 3. At the time of admission, the following questions were framed as substantial questions of law arising from the order of the Tribunal for consideration in this appeal : "(1) Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was legally justified in law in deleting the dis-allowances of Rs. 1,50,000 made by the Assessing Officer and confirmed by the Commissioner of Income-tax (Appeals) even though the assessee failed to establish that the payment made to State Polo Club alleged to be the fee for the sponsorship of Mewar OMS Trophy had any element of publicity or advertisement of its hotel business ? (2) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally justified in holding that the assessee is entitled for depreciation on imported motor cars at full rate in spite of the specific provisions of section 32(1)(ii) of the Income-tax Act, even though the assessee is not engaged in the business of cars on hire ? (3) Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was legally justified in holding that the assessee is entitled for higher rate of depreciation on Indian cars even though the assessee is not engaged in the business of running the cars on hire ?" 4. So far as questions Nos. 2 and 3 are concerned, it is common ground between the parties that these questions stand concluded in favour of the assessee and against the Revenue by a judgment of this court in CIT v. Lake Palace Hotels and Motels P. Ltd. reported in [2006] 286 ITR 589 in the present assessee's own case for different assessment years. The claim relates to deduction on depreciation of imported motor cars claimed by the assessee at full rate and in respect of the Indian motor cars at higher rate. 5. In view of the aforesaid decision, we do not find any merit in the contention of learned counsel for the appellant relating to question Nos. 2 and 3 above. The claim relates to deduction on depreciation of imported motor cars claimed by the assessee at full rate and in respect of the Indian motor cars at higher rate. 5. In view of the aforesaid decision, we do not find any merit in the contention of learned counsel for the appellant relating to question Nos. 2 and 3 above. No interference in the matter of allowing the claim of depreciation by the Tribunal on imported cars as well as Indian made cars is made out. 6. Coming to question No. 1, it may be noticed that the assessee has claimed a deduction of Rs. 1,50,000 by way of expenses incurred on sponsorship of State Polo Club tournament by providing Mewar OMS Polo Trophy. The Assessing Officer has opined that the activity of sports and the assessee's business have no connection and, therefore, the sponsorship of the tournament is not fully associated with the business promotion of the assessee so as to fall within section 10(2)(xv) of the Income-tax Act. The Tribunal, however, found that the sponsorship of the tournament by the assessee was purely motivated by business interest of the assessee inasmuch as the sponsorship of tournament carries high potential advertisement value for the business of the assessee and the activity is thus part of the business of the assessee. Sponsorship and holding of a tournament by awarding a trophy of one's trade name is an activity which number of persons witness and the display of the business name as well as the name of the trophy attached with the assessee's name provides enough advertisement value in promoting the business of the assessee. 7. We are of the opinion that the conclusion reached by the Tribunal in considering the sponsorship of the polo club tournament by holding Mewar OMS Polo Trophy by way of advertisement expenses to promote the business of the assessee was a finding correctly reached by the Tribunal. The fact is now so much well established in the commercial world that a judicial notice can be taken thereof that all major tournaments world over are sponsored by one or the other business houses purely to further their business interest. This is an activity of business promotion through advertisement which the sponsoring of the tournaments carries with it. 8. The fact is now so much well established in the commercial world that a judicial notice can be taken thereof that all major tournaments world over are sponsored by one or the other business houses purely to further their business interest. This is an activity of business promotion through advertisement which the sponsoring of the tournaments carries with it. 8. If any precedent is needed, the decision rendered by the Delhi High Court in CIT v. Delhi Cloth and General Mills Co. Ltd. reported in [1978] 115 ITR 659 may be noticed wherein the assessee-company was running a number of mills. The assessee-company was also organising all India tournaments in hockey and football. The question arose whether the expenditure incurred by the assessee-company in organising and sponsoring such sports tournaments could be allowed as business expenditure in terms of section 10(2)(xv) of the Indian Income-tax Act of 1922. Section 10(2)(xv) of the Act of 1922 is the corresponding section of section 37 of the Income-tax Act, 1961. In the aforesaid decision, the Bench of the Delhi High Court upheld the Tribunal's finding that by holding the tournament the assessee got publicity for its business and the reports in the newspapers went a long way to make the assessee a household word and also provided opportunity to the employees of the mills to participate and witness such tournaments which was an amenity very necessary in modern times and thus holding the tournament was helpful to the business interest of the assessee. 9. It is no gainsaying that sponsoring of a tournament in which the display of the sponsor's name and banners with the name of the assessee-company attached with the trophy would receive wide publicity through newspaper reports and, in itself, thus establishes the advertisement value which the assessee will get to promote its business. 10. We are in agreement with the Tribunal's finding that the expenses incurred by the assessee for sponsoring the trophy had the ingredient of advertisement of its business and, consequently, the assessee's claim to deduction as expenses wholly and exclusively incurred for the purpose of its business is justified. 11. 10. We are in agreement with the Tribunal's finding that the expenses incurred by the assessee for sponsoring the trophy had the ingredient of advertisement of its business and, consequently, the assessee's claim to deduction as expenses wholly and exclusively incurred for the purpose of its business is justified. 11. It will be profitable to notice here that the Tribunal itself has confirmed disallowance of deductions in respect of a benefit match in the assessment order of the previous year in which neither the name of the assessee was published in the brochure issued on the eve of the benefit match nor was it established by any evidence that such expenditure was in the nature of business advertisement. Thus, the distinction reflects the real nature of the sponsorship value. Where the sponsorship carries the advertisement of the business it carries advertisement value for promoting the business. 12. In view of the aforesaid finding, this appeal fails and is hereby dismissed. No costs. *******