Commissioner of Inland Revenue v. Mitsubishi Motors, New Zealand

222 ITR 697Reported decision1996#17256 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2008 to 2024.

Judgments citing Commissioner of Inland Revenue v. Mitsubishi Motors, New Zealand

Pr. Commissioner of Income Tax -7, Delhi vs. Sony India Pvt. Ltd

Appeal is dismissed

ITA-551/2023HC Delhi30 Sept 2024

Section 115JSection 143(3)Section 144C(13)Section 260A

…Court in Commissioner of Income Tax Vs. Vinitec Corpn (P.) Ltd, 278 ITR 337. This Court has relied upon the decision of the Supreme Court in Bharat Earth Movers Vs. CIT, 245 ITR 428 and Commissioner of Inland Revenue v. Mitsubishi Motors New Zealand Ltd., 222 ITR 697 held that the liability arising out of a warranty is an allowable deduction even when the amount payable by the assessee is quantified and discharged in future. The following passage from the above decision is in this regard apposite: “The ratio decidendi of the above cases is squarely applicable to the facts of the present case. It is not…

Sony India Pvt. Ltd., New Delhi vs. Natioanal E- Assesment Centre, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 493/DEL/2021[2016-17]Status: FixedITAT Delhi17 Oct 2022AY 2016-17

Bench: Shri Chandra Mohan Garg & Shri N.K. Billaiya

For Appellant: Shri Nageshwar Rao, AdvFor Respondent: Shri Bhaskar Goswami, CIT- DR

Section 115JSection 143(3)Section 80G

…e light of a Division Bench of this Court in CIT v. Vinitec Corpn (P.) Ltd [2005] 278 ITR 337 '. This Court has relied upon the decision of the Supreme Court in Bharat Earth Movers v. C/7[2000] 245 1 PR 428 and IRC v. Mitsubishi Motors New Zealand Ltd. [1996] 222 ITR 697 (PC) held that the liability arising out of a warranty is an allowable deduction even when the amount payable by the assessee is quantified and discharged in future. The following passage from the above decision is in this regard apposite: ”14. The ratio decidendi of the above cases is squarely applicable to the facts of the present case. It is…

M/S. Rotork Controla India (P) Ltd vs. Commnr. of Income Tax, Chennai

Appeals stand allowed in favour of the assessee with no order as to

C.A. No.-003506-003510 - 2009Supreme Court12 May 2009

Section 37

…scapement of income from assessment and the entire exercise would be revenue neutral. Learned counsel placed reliance on the judgment of the Privy Council in the case of Commissioner of Inland Revenue v. Mitsubishi Motors New Zealand Ltd. - (1996) 222 ITR 697 (PC). Learned counsel also placed reliance on the judgments of the Supreme Court in the case 1 of Bharat Earth Movers v. Commissioner of Income-tax – (2000) 245 ITR 428 (SC) and Metal Box Company of India Ltd. v. Their Workmen – (1969) 73 ITR 53 (SC). 7. Learned counsel next submitted that assuming for the sake of argument that the l…

Commissioner of Income Tax vs. Hewlett Packard (India) Ltd

The appeal is dismissed

ITA - 943 / 2007HC Delhi31 Mar 2008

…ill be discharged at a future date. It does not make any difference if the future date on which the liability shall have to be discharged is not certain." 13. Reference was also made to Commissioner of Inland Revenue v. Mitsubishi Motors, New Zealand, [1996] 222 ITR 697 (PC). Relying upon these two decisions and the facts noted above as well as the fact that the Assessee follows the mercantile system of accounting, the Tribunal held that the provision for warrantee claims was justified and is entitled to a deduction. (4) W ![](_page_7_Picture_1.jpeg) - 14. On the issue of the basis of estimating the liability…

Commissioner of Income Tax vs. Hewlett Packard (India) Ltd

The appeal is dismissed

ITA - 934 / 2007HC Delhi31 Mar 2008

…ill be discharged at a future date. It does not make any difference if the future date on which the liability shall have to be discharged is not certain." 13. Reference was also made to Commissioner of Inland Revenue v. Mitsubishi Motors, New Zealand, [1996] 222 ITR 697 (PC). Relying upon these two decisions and the facts noted above as well as the fact that the Assessee follows the mercantile system of accounting, the Tribunal held that the provision for warrantee claims was justified and is entitled to a deduction. 30 Ŕ. ![](_page_7_Picture_1.jpeg) - On the issue of the basis of estimating the liability, t…