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    <title>Scientific warranty estimation, grossed-up royalty tax and eligible in-house research expenditure deductions were accepted; notice-format challenge failed.</title>
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    <description>Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient&#039;s tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.</description>
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    <pubDate>Sat, 01 Aug 2026 08:34:29 +0530</pubDate>
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      <title>Scientific warranty estimation, grossed-up royalty tax and eligible in-house research expenditure deductions were accepted; notice-format challenge failed.</title>
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      <description>Scientific warranty provisions for automotive products may be deductible where liability arises on each sale and the provision is consistently estimated from historical experience, applying accrual and matching principles. Grossed-up withholding tax borne under an intellectual-property royalty agreement may form part of royalty consideration where the payer contractually assumes the foreign recipient&#039;s tax liability. For approved in-house research and development facilities, weighted deduction may cover eligible scientific-research expenditure actually incurred and cannot be restricted solely to the amount certified by DSIR. A challenge to the prescribed format of a notice under section 143(2) was rejected. The reported appeals were partly allowed, with the three expenditure disallowances deleted.</description>
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