https://www.taxtmi.com/caselaws?id=459450 ITAT Bangalore dismissed Revenue's appeal regarding DRP's jurisdiction under section 154 for TP adjustments. The assessee company had filed complete details of AMP expenditure including sales discount, selling expenditure, and warranty expenditure, which DRP initially failed to consider. Upon review, DRP modified directions excluding these items from AMP expenditure following precedent. ITAT held this constituted mistake apparent from record, justifying DRP's section 154 jurisdiction. Regarding warranty provision, ITAT found provision was based on reliable estimates using historical trends and percentage of sales, with actual claims closely matching provisions made in preceding years, making the provision allowable as deduction. en-us Mon, 07 Mar 2016 00:00:00 +0530 Fri, 13 Dec 2024 19:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459450 ITAT Bangalore dismissed Revenue's appeal regarding DRP's jurisdiction under section 154 for TP adjustments. The assessee company had filed complete details of AMP expenditure including sales discount, selling expenditure, and warranty expenditure, which DRP initially failed to consider. Upon review, DRP modified directions excluding these items from AMP expenditure following precedent. ITAT held this constituted mistake apparent from record, justifying DRP's section 154 jurisdiction. Regarding warranty provision, ITAT found provision was based on reliable estimates using historical trends and percentage of sales, with actual claims closely matching provisions made in preceding years, making the provision allowable as deduction. Case-Laws Income Tax Mon, 07 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459450