Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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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