https://www.taxtmi.com/caselaws?id=57767 Provision for warranty was held to be an accrued and certain liability embedded in sale price; only quantification was estimated on past experience, so it was not a contingent liability and the deduction was allowed, subject to ensuring no double deduction on actual outgo. Travelling expense disallowance under r. 6D was sustained at a lump sum since the assessee sought ad hoc computation and enhanced limits were inapplicable for the year, so partial disallowance remained. For s. 80-IA, direct costs were to be directly attributed and common/indirect costs reasonably allocated on wages/sales; the AO was directed to accept the assessee's computation, allowing the deduction. Compensation and information-transition payments were held revenue (no asset/enduring benefit) and allowed. Payment to a foreign collaborator was allowed 50% as revenue and 50% treated as capital. For s. 80HHE, "total turnover" was confined to software/technical-services turnover, excluding unrelated turnover, and recomputation was directed. For s. 80-O read with s. 80AB, only direct expenses could be reduced; no estimated offshore expenses were permitted, and deduction was directed accordingly. en-us Mon, 08 Jul 2002 00:00:00 +0530 Fri, 26 Dec 2025 17:02:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57767 Provision for warranty was held to be an accrued and certain liability embedded in sale price; only quantification was estimated on past experience, so it was not a contingent liability and the deduction was allowed, subject to ensuring no double deduction on actual outgo. Travelling expense disallowance under r. 6D was sustained at a lump sum since the assessee sought ad hoc computation and enhanced limits were inapplicable for the year, so partial disallowance remained. For s. 80-IA, direct costs were to be directly attributed and common/indirect costs reasonably allocated on wages/sales; the AO was directed to accept the assessee's computation, allowing the deduction. Compensation and information-transition payments were held revenue (no asset/enduring benefit) and allowed. Payment to a foreign collaborator was allowed 50% as revenue and 50% treated as capital. For s. 80HHE, "total turnover" was confined to software/technical-services turnover, excluding unrelated turnover, and recomputation was directed. For s. 80-O read with s. 80AB, only direct expenses could be reduced; no estimated offshore expenses were permitted, and deduction was directed accordingly. Case-Laws Income Tax Mon, 08 Jul 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57767