Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Steel-timber construction shuttering/formwork tariff classification dispute: essential character held steel, classified as shuttering under Heading 73...
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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