https://www.taxtmi.com/caselaws?id=257737 The Tribunal allowed the Assessee's appeal in a case concerning the disallowance of 'brand owner's surplus' and ROC fee payment under section 263 of the I.T. Act, 1961. The Tribunal held that the liability was ascertained based on the agreement, even though there was a dispute over quantification. It disagreed with the Ld. CIT's view that the liability was contingent, emphasizing that if a business liability arises in an accounting year, deduction should be allowed. The Tribunal considered the Ld. CIT's direction as a change of opinion and directed the A.O. to allow the amount as originally assessed. en-us Fri, 18 Jul 2014 00:00:00 +0530 Sat, 21 Mar 2015 06:11:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257737 The Tribunal allowed the Assessee's appeal in a case concerning the disallowance of 'brand owner's surplus' and ROC fee payment under section 263 of the I.T. Act, 1961. The Tribunal held that the liability was ascertained based on the agreement, even though there was a dispute over quantification. It disagreed with the Ld. CIT's view that the liability was contingent, emphasizing that if a business liability arises in an accounting year, deduction should be allowed. The Tribunal considered the Ld. CIT's direction as a change of opinion and directed the A.O. to allow the amount as originally assessed. Case-Laws Income Tax Fri, 18 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257737