TITAN COMPANY LIMITED 9EARSTWHILE KNOWN AS TITAN INDUSTRIES LIMITED),KRISHNAGIRI vs. ACIT LTU 1, CHENNAI

ITA 518/CHNY/2018Status: DisposedITAT Chennai29 May 2024AY 2009-10Bench: SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI AMITABH SHUKLA (Accountant Member)43 pages
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What did the Tribunal hold?

The Tribunal held that the provision for customer loyalty programs was based on a scientific method and allowed the claim. It also ruled that UPS is an integral part of computers and eligible for 60% depreciation, directing the AO to allow the claim.

What were the facts?

The assessee company made provisions for customer loyalty programs and claimed depreciation on UPS. The Assessing Officer (AO) and Commissioner of Income Tax (Appeals) disallowed these claims, arguing the provision was not scientific and UPS was not eligible for higher depreciation.

What were the issues?

Whether the provision for customer loyalty programs is an allowable expenditure, and whether UPS qualifies for depreciation at 60% as part of computers.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 115JB

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Income Tax Appellate Tribunal, ‘D’ BENCH, CHENNAI

Before: SHRI MAHAVIR SINGHAND

Hearing: 29.04.2024Pronounced: 29.05.2024

PER MAHAVIR SINGH, VICE PRESIDENT:

These appeals by the assessee are arising out of the common order of the Commissioner of Income Tax (Appeals)-17, Chennai in ITA Nos. 28 & 27/14-15 & 3/15-16 dated 11.12.2017. The ITA Nos.518, 505, 506 & 507/Chny/2020

assessments were frame

The order continues below.

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