Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
A provision for warranty computed by reference to past experience and a scientific estimation constitutes a present obligation and therefore an ascertained liability; it does not qualify as an amount set aside for unascertained liabilities and so is not subject to add-back in the computation of book profit under the tax regime's alternate profit measure. Reliance on prior higher court authority supporting allowance where liabilities are reasonably estimable was applied. The addition of the warranty provision to book profit was deleted, and the deletion of the addition under the normal tax provisions was sustained against Revenue's challenge.
A provision for warranty computed by reference to past experience and a scientific estimation constitutes a present obligation and therefore an ascertained liability; it does not qualify as an amount set aside for unascertained liabilities and so is not subject to add-back in the computation of book profit under the tax regime's alternate profit measure. Reliance on prior higher court authority supporting allowance where liabilities are reasonably estimable was applied. The addition of the warranty provision to book profit was deleted, and the deletion of the addition under the normal tax provisions was sustained against Revenue's challenge.
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