Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Disallowance of a warranty provision under tax law was contested; ITAT found the provision was based on historical experience and year-wise working, demonstrating obligating events and consistent utilization (warranty utilized Rs.58,05,616). The tribunal rejected revenue's assertion that an adequate opening balance alone eliminated the need for additional provisioning, holding that provisions founded on estimation of obligation and outflow need not be disturbed. Reliance on similar group-entity precedent confirming a scientific basis for warranty provisioning supported allowing the assessee's claim, and the appeal was allowed.
Disallowance of a warranty provision under tax law was contested; ITAT found the provision was based on historical experience and year-wise working, demonstrating obligating events and consistent utilization (warranty utilized Rs.58,05,616). The tribunal rejected revenue's assertion that an adequate opening balance alone eliminated the need for additional provisioning, holding that provisions founded on estimation of obligation and outflow need not be disturbed. Reliance on similar group-entity precedent confirming a scientific basis for warranty provisioning supported allowing the assessee's claim, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
