https://www.taxtmi.com/caselaws?id=448627 ITAT Chennai upheld disallowance of warranty provision as it lacked scientific basis per SC precedent in Rotork Control India case. For contract contingencies provision, tribunal directed AO to recompute addition correctly. Trademark payment issue was remanded for fresh examination after assessee provided registration documents. Regarding TDS on non-resident payments, tribunal allowed payments to German company citing retrospective amendment impossibility, and upheld CIT(A)'s deletion of Swiss company payment disallowance as reimbursement without markup doesn't constitute fees for technical services. Depreciation on goodwill and non-compete fee was allowed based on previous favorable decisions. TDS demand under sections 201(1) and 201(1A) was deleted following main assessment findings. en-us Mon, 20 Nov 2023 00:00:00 +0530 Wed, 24 Jan 2024 09:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448627 ITAT Chennai upheld disallowance of warranty provision as it lacked scientific basis per SC precedent in Rotork Control India case. For contract contingencies provision, tribunal directed AO to recompute addition correctly. Trademark payment issue was remanded for fresh examination after assessee provided registration documents. Regarding TDS on non-resident payments, tribunal allowed payments to German company citing retrospective amendment impossibility, and upheld CIT(A)'s deletion of Swiss company payment disallowance as reimbursement without markup doesn't constitute fees for technical services. Depreciation on goodwill and non-compete fee was allowed based on previous favorable decisions. TDS demand under sections 201(1) and 201(1A) was deleted following main assessment findings. Case-Laws Income Tax Mon, 20 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448627