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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.
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