https://www.taxtmi.com/caselaws?id=767776 ITAT Mumbai allowed the assessee's appeal regarding provision for claim payout deduction. The tribunal overturned CIT(A)'s finding that provisions were created on adhoc basis, noting that actual claim payouts exceeded provisions created for AY 2019-20, and aggregate difference between provisions and actual payouts from AY 2016-17 to 2022-23 was only 2.21%. The tribunal held that provisions were based on actuarial reports by independent actuaries and constituted ascertained liability under trust deed, scheme, and applicable agreements. AO and CIT(A) orders were set aside, with directions to allow deduction for claim payout provisions. The decision was supported by precedents from Credit Guarantee Fund cases. The assessee was also granted income tax exemption under section 10(46B) by Finance Act 2023. en-us Fri, 21 Mar 2025 00:00:00 +0530 Mon, 21 Jul 2025 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767776 ITAT Mumbai allowed the assessee's appeal regarding provision for claim payout deduction. The tribunal overturned CIT(A)'s finding that provisions were created on adhoc basis, noting that actual claim payouts exceeded provisions created for AY 2019-20, and aggregate difference between provisions and actual payouts from AY 2016-17 to 2022-23 was only 2.21%. The tribunal held that provisions were based on actuarial reports by independent actuaries and constituted ascertained liability under trust deed, scheme, and applicable agreements. AO and CIT(A) orders were set aside, with directions to allow deduction for claim payout provisions. The decision was supported by precedents from Credit Guarantee Fund cases. The assessee was also granted income tax exemption under section 10(46B) by Finance Act 2023. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767776