Rotork Controls India Pvt. Ltd. v. CIT

314 ITR 62Supreme Court of India2009#69 most cited

What is Rotork Controls India Pvt. Ltd. v. CIT authority for?

A provision for expenses, such as warranty, is a deductible liability for income tax purposes if it constitutes a present obligation arising from past events, and a reliable estimate of the amount of obligation is possible.

739

judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2009 to 2026.

Also referred to as

Rotork Controls India Pvt. Ltd. v. CIT · 314 ITR 62 · Section 37(1) · provision for warranty expenses · allowability of provision · definition of liability · present obligation · reliable estimate · mercantile system of accounting · revenue expenditure deduction

Also reported as

223 CTR 425

Sections most often in play

Section 143(3)Section 37(1)Section 40(a)(ia)Section 115JBSection 14ASection 147Section 234CSection 40(a)(i)

Issues it is cited on

section 35denduring benefitsection 32(1)put to useblock of assetssection 40(a)(i)intangible assetsmercantile system of accountingsection 35section 37(1)section 32revenue expenditure

Judgments citing Rotork Controls India Pvt. Ltd. v. CIT

DCIT, Cir. 7(1), Kolkata vs. M/S Bch Electric Ltd, Kolkata

In the result, the appeal filed by the Revenue is dismissed

ITA 4/KOL/2021[2005-06]Status: DisposedITAT Kolkata31 Mar 2022AY 2005-06

Bench: Sri Rajpal Yadav & Sri Manish Borad)

Section 143(1)Section 147

…see in the earlier years. The Ld. CIT(A) by following order of his predecessor in assessee’s own case for the assessment year 2007-08 and respectfully following the decision of Hon'ble Supreme Court in the case of CIT vs. Rotork Control India Ltd. reported in 314 ITR 62 (SC) held that the assessee had made provision for warranty on a scientific basis and accordingly is eligible for deduction for the same in the year of making the provision. Aggrieved the revenue is in appeal before us on the following grounds: 3. That on the facts and in the circumstances of the case and in law, the Ld. CIT(Appeals) erred in dele…

DCIT, Chennai vs. Avalon Technologies P. Ltd., Chennai

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

ITA 214/CHNY/2017[2009-10]Status: DisposedITAT Chennai31 Mar 2022AY 2009-10

Bench: Shri Mahavir Singhand Dr. M.L. Meena

For Respondent: Shri Guru Bashyam, CIT
Section 10ASection 143(3)

…de for market to market losses adjustment made for assessment years 2009-10 & 2010-11, which are illustrative only. We noted that this issue has been dealt with by Hon’ble Supreme Court in the case of Rotork Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) wherein the Hon’ble Supreme Court explained that a provision is a liability which can be measured only by using a substantial degree of estimation. The Hon’ble Supreme Court had laid down 3 conditions for recognizing a provision: a. An enterprise has a present obligation as result of past event. b. It is probable that an out flow of resources…

Avalon Technoloiges (P) Limited, Chennai vs. DCIT, Chennai

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

ITA 445/CHNY/2016[2010-11]Status: DisposedITAT Chennai31 Mar 2022AY 2010-11

Bench: Shri Mahavir Singhand Dr. M.L. Meena

For Respondent: Shri Guru Bashyam, CIT
Section 10ASection 143(3)

…de for market to market losses adjustment made for assessment years 2009-10 & 2010-11, which are illustrative only. We noted that this issue has been dealt with by Hon’ble Supreme Court in the case of Rotork Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) wherein the Hon’ble Supreme Court explained that a provision is a liability which can be measured only by using a substantial degree of estimation. The Hon’ble Supreme Court had laid down 3 conditions for recognizing a provision: a. An enterprise has a present obligation as result of past event. b. It is probable that an out flow of resources…

Avalon Technologies (P) Limited, Chennai vs. DCIT, Chennai

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

ITA 1775/CHNY/2016[2009-10]Status: DisposedITAT Chennai31 Mar 2022AY 2009-10

Bench: Shri Mahavir Singhand Dr. M.L. Meena

For Respondent: Shri Guru Bashyam, CIT
Section 10ASection 143(3)

…de for market to market losses adjustment made for assessment years 2009-10 & 2010-11, which are illustrative only. We noted that this issue has been dealt with by Hon’ble Supreme Court in the case of Rotork Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) wherein the Hon’ble Supreme Court explained that a provision is a liability which can be measured only by using a substantial degree of estimation. The Hon’ble Supreme Court had laid down 3 conditions for recognizing a provision: a. An enterprise has a present obligation as result of past event. b. It is probable that an out flow of resources…

M/S Continental Automotive Components India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-2(1)(1), Bangalore

In the result, the appeal is partly allowed

ITA 129/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Mar 2022AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year :2014-15 M/S. Continental Automotive Vs. Dcit, Components India Pvt. Ltd., Circle – 2(1)(1), Plot No.53B, Bommasandra Industrial Bengaluru. Area, Hosur Road, Attibele Hobli, Anekal Taluk, Bengaluru–560 099. Pan : Aakcs 9578 C Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Shri. Mudavathu Harish Chandra Naik, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 21.03.2022 Date Of Pronouncement : 29.03.2022 O R D E R

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Shri. Mudavathu Harish Chandra Naik, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER Assessment Year :2014-15 M/s. Continental Automotive Vs. DCIT, Components India Pvt. Ltd., Circle – 2(1)(1), Plot No.53B, Bommasandra Industrial Bengaluru. Area, Hosur Road, Attibele Hobli, Anekal Taluk, Bengaluru–560 099. PAN : AAKCS 9578 C APPELLANT RESPONDENT Assessee by : Shri. T. Suryanarayana, Senior Advocate Revenue by : Shri. Mudavathu Harish Chandra Naik, CIT(DR)(ITAT), Bengaluru. Date of hearing : 21.03.2022 Date of Pronouncement : 29.03.2022 O R D E R Per N.…

Centum Learning Ltd., New Delhi vs. DCIT, Circle-5(2), New Delhi

In the result, for the statistical purposes, this appeal is

ITA 5067/DEL/2018[2013-14]Status: DisposedITAT Delhi24 Mar 2022AY 2013-14
Section 143(3)Section 145Section 14ASection 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI (Through Video Conferencing) BEFORE, SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER M/s Centum Learning Dy. Commissioner of Limited Income Tax, Circle-5(2), 127, Neelagagan, New Delhi. Mandi Road Sultanpur, Vs. Mehrauli, New Delhi-110 030. PAN-AADCB 3842R (Appellant) (Respondent) Appellant By Sh. Sh. Anil Bhalla, CA Respondent by Ms. Yagya Saini Kakkar, CIT- DR ORDER PER ANADEE NATH MISSHRA, AM: (A) This appeal by Assessee is filed against the order of Learned Commissioner of Income Tax (Appeals)…

Dhanraj Chhaganlal Shah, Pune vs. Deputy Commissioner of Income-Tax, Circle - 6, Pune

In the result, the appeal of the Revenue in ITA

ITA 1802/PUN/2017[2014-15]Status: DisposedITAT Pune23 Mar 2022AY 2014-15
For Appellant: Shri Bharat ShahFor Respondent: Shri M. Jasnani
Section 133(6)Section 143(3)Section 41(1)Section 68Section 69C

…from the Provision granted relief. 21. Being aggrieved, the Revenue is in appeal before us. 22. The ld. Sr. DR submitted that the ld. CIT(A) without considering the decision of the Hon’ble Supreme Court in the case of Rotork Controls India (P.) Ltd. vs. CIT, 314 ITR 62 (SC) has allowed the Provision for warrant as a deduction. 23. On the other hand, ld. AR submitted that Provision for warranty was not debited from the Profit & Loss Account and, therefore, no claim for warranty expenditure was made. When no claim for allowance for Provision for warranty was made, the question of addition does not arise. 24. We he…

Assistant Commissioner of Income-Tax, Circle - 6, Pune vs. Dhanraj Chhaganlal Shah, Pune

In the result, the appeal of the Revenue in ITA

ITA 2027/PUN/2017[2014-15]Status: DisposedITAT Pune23 Mar 2022AY 2014-15
For Appellant: Shri Bharat ShahFor Respondent: Shri M. Jasnani
Section 133(6)Section 143(3)Section 41(1)Section 68Section 69C

…from the Provision granted relief. 21. Being aggrieved, the Revenue is in appeal before us. 22. The ld. Sr. DR submitted that the ld. CIT(A) without considering the decision of the Hon’ble Supreme Court in the case of Rotork Controls India (P.) Ltd. vs. CIT, 314 ITR 62 (SC) has allowed the Provision for warrant as a deduction. 23. On the other hand, ld. AR submitted that Provision for warranty was not debited from the Profit & Loss Account and, therefore, no claim for warranty expenditure was made. When no claim for allowance for Provision for warranty was made, the question of addition does not arise. 24. We he…

Racold Thermo Private Limited (Formerly Known As Racold Thermo Limited), Pune vs. Deputy Commissioner of Income Tax

In the result, the appeal filed by assessee stands partly allowed for statistical purposes

ITA 2920/PUN/2016[2009-10]Status: DisposedITAT Pune22 Mar 2022AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Respondent: Shri Ketan Ved
Section 143(3)

…sed as Annexure-1 Accordingly, it is respectfully submitted that the provision for warranty is made on scientific basis, past historical trend and in accordance with the law laid down by the Supreme Court in the cast of Rotork Controls India (P.) Ltd. v. CIT 314 ITR 62 (SC)…..” 3. It is claimed that the above method of working for the provision of warranty is based on scientific method, past historical data, which is in consonance with the ratio laid down by the Hon'ble Supreme Court in Rotork Controls India (P.) Ltd. vs. CIT 314 ITR 62 (SC). However, the above submission of assessee had been rejected by the A…

Racold Thermo Private Limited (Formerly Known As Racold Thermo Limited), Pune vs. Deputy Commissioner of Income Tax, Pune

In the result, the appeal filed by assessee stands partly allowed for statistical purposes

ITA 499/PUN/2017[2011-12]Status: DisposedITAT Pune22 Mar 2022AY 2011-12

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Respondent: Shri Ketan Ved
Section 143(3)

…sed as Annexure-1 Accordingly, it is respectfully submitted that the provision for warranty is made on scientific basis, past historical trend and in accordance with the law laid down by the Supreme Court in the cast of Rotork Controls India (P.) Ltd. v. CIT 314 ITR 62 (SC)…..” 3. It is claimed that the above method of working for the provision of warranty is based on scientific method, past historical data, which is in consonance with the ratio laid down by the Hon'ble Supreme Court in Rotork Controls India (P.) Ltd. vs. CIT 314 ITR 62 (SC). However, the above submission of assessee had been rejected by the A…

M/S Lenovo India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-4(1)(1), Bangalore

In the result, the appeal filed by assessee stands allowed

ITA 2833/BANG/2017[2013-14]Status: DisposedITAT Bangalore21 Mar 2022AY 2013-14
For Appellant: Shri Padamchand Khincha, CA
Section 143(3)Section 144C(13)Section 92C

…computation of provision for warranty based on such methodology and as per the principles laid down by the Page 26 of 37 IT(TP)A No. 2833/Bang/2017 Hon’ble Supreme Court in the case of Rotork Controls India Pvt. Ltd. vs. CIT, reported in [2009] 180 Taxman 422/314 ITR 62 (SC) was also submitted. Assessee also relied on the decision of coordinate bench of this Tribunal in assessee’s own case for AY 2006-07 and AY 2011-12, wherein it was held that the assessee has followed a scientific methodology for creation of provision for warranty was also submitted. The Ld.AO however rejected the submissions of assessee and de…

Dy CIT - 8(3)(1), Mumbai vs. M/S Tata Aig General Insurance Co.Ltd., Mumbai

In the result, ground No. 3 of the appeal is dismissed

ITA 14/MUM/2021[2015-16]Status: DisposedITAT Mumbai08 Mar 2022AY 2015-16

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am The Dy. Commissioner Of M/S Tata Aig General Income Tax-8(3)(1), Insurance Co. Ltd. 15Th Floor, Tower A, Aayakar Bhavan, Room No. 615, Peninsula Corporate Park, Vs. M.K. Road, G.K. Marg, New Marine Lines, Mumbai- Lower Parel, 400 020 Mumbai-400 013 (Appellant) (Respondent) Pan No. Aabct3518Q Appellant By : Shri Rajesh Damor, Cit Dr Respondent By : S/Shri J.D. Mistry & Madhur Agrawal, Ars’ Date Of Hearing: 23.12.2021 Date Of Pronouncement : 08.03.2022

For Appellant: Shri Rajesh Damor, CIT DRFor Respondent: S/Shri J.D. Mistry & Madhur
Section 143(3)Section 32Section 37(1)Section 40Section 44

…e Co. Ltd.; AY 15-16 supported by the actual valuation and hence, he disallowed ₹148,43, 01,915/-. The ld CIT (A) after considering the decision of the honourable Supreme Court in case of Rotork controls India private limited versus Commissioner of income tax 314 ITR 62 considered that if there is a present obligation with respect to the provision, and it arises out of events involving outflow of resources and can be based on reliable estimation of such obligation then the liability incurred by the assessee company is allowable. He further held that the methodology to determine the liability is also certified by…

DCIT 3(3)(2), Mumbai vs. M/S Sky Appliances Ltd, Mumbai

Appeal is allowed

ITA 4707/MUM/2019[2014-15]Status: DisposedITAT Mumbai08 Mar 2022AY 2014-15

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2014-15

For Appellant: NoneFor Respondent: Shri B.K. Bagchi, D.R
Section 115JSection 14A

…of Rs.2,70,13,460/- without appreciating that the assessee had not furnished the requisite details and documentary evidence for the claim and that the claim did not satisfy the methodology prescribed by the Apex Court in Rotork Controls India (P) Ltd. vs. CIT314 ITR 62 (SC) 5. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in allowing the provisions for warranty and maintenance expenses of Rs.2,70,13,460/- without appreciating the fact that such 3 M/s. Sky Appliances Ltd. provision is an unascertained liability, created for future utilization and the AO has ri…

Socomec Innovative Power Solutions Private Limited, Chennai vs. ACIT (OSD), Corporate Circle-6, Chennai

The appeal stands allowed in terms of our above order

ITA 1748/CHNY/2019[2011-12]Status: DisposedITAT Chennai04 Mar 2022AY 2011-12

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Ajit Tolani (Advocate) – Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) –Ld. DR
Section 143(3)

…आयकर अपीलीय अिधकरण ‘बी’"ायपीठ चे"ई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHENNAI माननीय-ीमहावीरिसंह, उपा34एवं माननीय-ी मनोज कुमार अ9वाल ,लेखा सद< के सम4। BEFORE HON’BLE SHRI MAHAVIR SINGH, VICE PRESIDENT AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपीलसं./ITA No.1748/Chny/2019 (िनधाEरणवषE / Assessment Year: 2011-12) M/s. Socomec Innovative Power ACIT(OSD) Solutions Private Limited Corporate Circle 6, बनाम/ B-1, 2nd Floor, Jaleel Park, Room No. 718, 7th Floor Vs. Thiru-Vi-Ka Industrial Estate, Wanaparthy Block, Guindy,Chennai – 600 032. 121, M G Road, Chennai – 600 034. "थायीलेखासं./जीआइआरसं./PA…

Venture Lighting India Limited, Chennai vs. ACIT Corporate Circle 3(2), Chennai

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 1209/CHNY/2019[2010-11]Status: DisposedITAT Chennai04 Mar 2022AY 2010-11

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…n adhoc basis, contingent in nature and that there is no historic trend explained before us. We noted that the Hon’ble Supreme Court in the case of Rotork 13 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) has noted the issue regarding contingent liability like warranty provision and held that the value of contingent liability, like the warranty expenses, if properly ascertained and discounted on accrual basis can be claimed as item of deduction u/s.37(1) of the Act. But, Hon’ble Supreme Court stated that the principle of estimation of continge…

Venture Lighting India Limited, Chennai vs. ACIT Corporate Circle 3(2), Chennai

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 2946/CHNY/2018[2014-15]Status: DisposedITAT Chennai04 Mar 2022AY 2014-15

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…n adhoc basis, contingent in nature and that there is no historic trend explained before us. We noted that the Hon’ble Supreme Court in the case of Rotork 13 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) has noted the issue regarding contingent liability like warranty provision and held that the value of contingent liability, like the warranty expenses, if properly ascertained and discounted on accrual basis can be claimed as item of deduction u/s.37(1) of the Act. But, Hon’ble Supreme Court stated that the principle of estimation of continge…

Venture Lighting India Limited, Chennai vs. ACIT Corporate Circle 3(2), Chennai

In the result, considering the factual matrix in the instant case, material available on record and the judicial precedence discussed above, the appeals filed by the assessee in ITA Nos

ITA 2945/CHNY/2018[2012-13]Status: DisposedITAT Chennai04 Mar 2022AY 2012-13

Bench: Shri Mahavir Singhand Shri Girish Agrawalआयकर अपील सं./Ita Nos.: 2945 & 2946/Chny/2018 & 1209/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13, 2014-15 & 2010-11 The Acit / Dcit, M/S. Venture Lighting India Limited, Corporate Circle – 3(2), V. Plot No.A-30, D5, Phase-Ii, Chennai. Zone-B, Mepz, Tambaram, Chennai – 600 045. Pan: Aaaca 9284H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri G. Johnson, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 03.03.2022 घोषणा क" तार"ख/Date Of Pronouncement : 04.03.2022 आदेश /O R D E R Per Girish Agrawal, Am: The Two Appeals In Ita Nos. 2945 & 2946/Chny/2018 By The Assessee Are Arising Out Of Common Order Of Learned Commissioner Of Income Tax (Appeals)-11, Chennai In Ita Nos.112/16-17 & 160/17-18, Dated 29.09.2018. The Assessments Were Framed By The Acit / Dcit, Corporate Circle 3(2), Chennai For The Assessment Years 2012-13 &

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri G. Johnson, Addl.CIT
Section 143(3)

…n adhoc basis, contingent in nature and that there is no historic trend explained before us. We noted that the Hon’ble Supreme Court in the case of Rotork 13 I.T.A. Nos.2945 & 2946/Chny/2018 1209/Chny/2019 Controls India P. Ltd., vs. CIT, reported in [2009] 314 ITR 62 (SC) has noted the issue regarding contingent liability like warranty provision and held that the value of contingent liability, like the warranty expenses, if properly ascertained and discounted on accrual basis can be claimed as item of deduction u/s.37(1) of the Act. But, Hon’ble Supreme Court stated that the principle of estimation of continge…

American Power Conversion (India) Private Limited, Bangalore vs. Addl.C.I.T., Bangalore

In the result, appeal of the assessee stands partly allowed as indicated herein above

ITA 1111/BANG/2012[2008-09]Status: DisposedITAT Bangalore28 Feb 2022AY 2008-09

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 1111/Bang/2012 Assessment Year : 2008-09

For Appellant: Shri Ketan Ved, CA
Section 133(6)Section 143(3)Section 92C

…is concerned, we have heard the rival submissions. The conditions for allowing provision on account of provision for warranty expenses has been laid down by the Hon'ble Supreme Court in the case of Rotork Controls India (P.) Ltd. v. CIT [2009] 180 Taxman 422/314 ITR 62 wherein the Honorable Apex Court has stated that provision for warranty shall be allowed if it is made on scientific basis. The Assessee has filed a chart explaining as to how the Principles laid down by the Hon'ble Supreme Court in the case of Rotork Controls (supra) has been satisfied in its case. Principles laid down for provision for warranty…

Ingersoll - Rand International (India) Limited, Bangalore vs. DCIT, Bangalore

In the result, both the appeals of assessee as well as revenue are treated as allowed for statistical purposes

ITA 549/BANG/2015[2010-11]Status: DisposedITAT Bangalore21 Feb 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.549/Bang/2015 Assessment Year: 2010-11

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)Section 40

…IT(TP)A Nos.487 & 549/Bang/2015 Ingersoll Rand International India Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B.R. BASKARAN, ACCOUNTANT MEMBER IT(TP)A No.549/Bang/2015 Assessment Year: 2010-11 Ingersoll Rand International (India) Pvt. Ltd. (formerly known as Ingersoll Rand Deputy International (India) Limited) Commissioner of 8th Floor, Tower D, IBC Knowledge Park, Vs. Income-tax No.4/1, Bannerghatta Main Road Circle-3(1)(1) Bangalore Bangalore PAN NO :AABCI3371E APPELLANT RESPONDENT IT(TP)A No.487/Bang/2015 Assessment…

D.C.I.T., Bangalore vs. M/S Ingersoll - Rand International India Pvt. Ltd., Bangalore

In the result, both the appeals of assessee as well as revenue are treated as allowed for statistical purposes

ITA 487/BANG/2015[2010-11]Status: DisposedITAT Bangalore21 Feb 2022AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.549/Bang/2015 Assessment Year: 2010-11

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 143(3)Section 40

…IT(TP)A Nos.487 & 549/Bang/2015 Ingersoll Rand International India Pvt. Ltd., Bangalore IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B.R. BASKARAN, ACCOUNTANT MEMBER IT(TP)A No.549/Bang/2015 Assessment Year: 2010-11 Ingersoll Rand International (India) Pvt. Ltd. (formerly known as Ingersoll Rand Deputy International (India) Limited) Commissioner of 8th Floor, Tower D, IBC Knowledge Park, Vs. Income-tax No.4/1, Bannerghatta Main Road Circle-3(1)(1) Bangalore Bangalore PAN NO :AABCI3371E APPELLANT RESPONDENT IT(TP)A No.487/Bang/2015 Assessment…