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Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient's tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.
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