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 366,470 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

Dy. Commissioner of Income Tax, Central Circle-18, Delhi vs. M/S Delhivery Limited, Delhi

In the result ground no 8 of the appeal is allowed

ITA 573/DEL/2025[2020-21]Status: DisposedITAT Delhi13 Aug 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Ms Pooja Swaroop, CIT-DR &
Section 143(3)Section 37(1)

…isely possible at the time of incurring the liability would not make an ascertained liability a contingent. 9.3.4 Almost to the similar effect, there is another judgment of the Hon'ble Supreme Court in the case of Rotork Controls India (P.) Ltd. v. CIT [2009] 314 ITR 62/180 Таxman 422. In that case, the assessee-company was ITAs No.585 & 573/Del/2025 engaged in selling certain products. At the time of sale, the company provided a standard warranty that in the event of certain part becoming defective within 12 months from the date of commissioning or 18 months from the date of dispatch, whichever is earlier, the…

Dy. Commissioner of Income Tax Circle 10(1), Delhi, Cr Building vs. Indus Towers Limited, Gurgram

ITA 2805/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

…preciation thereon. Following the mercantile system of accounting and the law enunciated by the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd v. CIT [1997] 225 ITR 802 (SC) and Rotork Controls India (P.) Ltd. vs. CIT [2009] 314 ITR 62 (SC), such SRO is amortized over the tenure of the lease and claimed as business expenditure deductible. During the relevant assessment year, the assessee Page | 36 amortized Rs.101,11,00,000 in the books of accounts in respect of site restoration obligation. For the purposes of MAT, since ARO liability represents an ascertained liability, the sa…

Indus Towers Ltd., Gurugram, Haryana vs. Deputy Commissioner of Income-Tax, Circle 12(1), New Delhi

ITA 2607/DEL/2023[2011-12]Status: DisposedITAT Delhi08 Aug 2025AY 2011-12

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 142Section 143(3)

…preciation thereon. Following the mercantile system of accounting and the law enunciated by the Hon'ble Supreme Court in the case of Madras Industrial Investment Corporation Ltd v. CIT [1997] 225 ITR 802 (SC) and Rotork Controls India (P.) Ltd. vs. CIT [2009] 314 ITR 62 (SC), such SRO is amortized over the tenure of the lease and claimed as business expenditure deductible. During the relevant assessment year, the assessee amortized Rs.101,11,00,000 in the books of accounts in respect of site restoration obligation. For the purposes of MAT, since ARO liability represents an ascertained liability, the same has been…

Deputy Commissioner of Income Tax, Central Circle 6(3), Mumbai vs. Coimbatore Integrated Waste Management Company Private Ltd, Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 1021/MUM/2025[2018]Status: DisposedITAT Mumbai24 Jul 2025

Bench: Hon’Ble Shri Sandeep Gosain & Shri Prabhash Shankardcit, Cc – 6(3) Vs. Coimbatore Integrated Room No. 450, 4Th Floor, Waste Management Kautilya Bhawan, Bkc Company Pvt Ltd Mumbai – 400051. Kansas Avenue, Trilok Apartments, Civil Aerodrome P., Coimbatore South Pan/Gir No. Adcc3184B (Applicant) (Respondent)

Section 250

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER DCIT, CC – 6(3) Vs. Coimbatore Integrated Room No. 450, 4th Floor, Waste Management Kautilya Bhawan, BKC Company Pvt Ltd Mumbai – 400051. Kansas Avenue, Trilok Apartments, Civil Aerodrome P., Coimbatore South PAN/GIR No. ADCC3184B (Applicant) (Respondent) Assessee by Shri Kirit kamdar Revenue by Mr. Virabhadra S. Mahajan, Sr. DR Date of Hearing 02.07.2025 Date of Pronouncement 24.07.2025 आदेश / ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by th…

ACIT, Circle - 2(1), Kolkata vs. M/S. Bata India Ltd., Kolkata

Appeal is partly allowed and the CO is dismissed

ITA 1844/KOL/2017[2009-10]Status: DisposedITAT Kolkata23 Jul 2025AY 2009-10

Bench: the Hon'ble Income Tax Appellate Tribunal, Kolkata in ITA No. 1844/Kol/2017 for the assessment year 2009-10;

Section 143(3)Section 250Section 43B

…ranty was made by the assessee for relevant assessment year on a reasonable and scientific basis as worked out by the actuarial valuer on the basis of past return/replacement ratio. The Hon’ble Supreme Court in the case of Rotork Controls India Ltd. vs. CIT: 314 ITR 62 has held that the provision for warranty made on a scientific basis, is an ascertained liability deductible under section 37(1) of the Act. 4. We have carefully considered the rival submissions and have also gone through the orders of authorities below and the documents filed by both the AR and DR. Regarding Ground No. 1, it is obvious that if th…

Agappe Diagnostics Limited, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

In the result, the appeal is allowed

ITA 2621/MUM/2025[2021-22]Status: DisposedITAT Mumbai04 Jun 2025AY 2021-22

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: None. Written submission received byFor Respondent: Shri Aditya Rai, (Sr. DR)
Section 143(3)Section 37(1)

…pellant and therefore qualifies as an allowable business expenditure u/s.37(1). 3. Whether the Learned CIT(A) erred in not taking into consideration the binding decision of the Hon'ble Supreme Court in the case of Rotork Controls India Private Limited v. CIT (314 ITR 62), by incorrectly distinguishing it on facts. 4. Whether the Learned CIT(A) erred in stating that the appellant has not offered the excess of provision either in the current year or in the succeeding year. The Learned CIT(A) ought to have noted that if the amount claimed as expenses in a year exceeds the actual expenditure, the difference is revers…

Mahua Bharatpur Expressways Limited (Formerly Known As Madhucon Agra- Jaipur Expressways Limited), Hyderabad vs. ACIT, Circle-16(2), Hyderabad

In the result, Revenue appeals for the A

ITA 308/HYD/2021[2013-14]Status: DisposedITAT Hyderabad02 Jun 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15)

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: Shri B Balakrishna, CIT (DR)
Section 43Section 43(1)

…ITA Nos 285 286 of 2018 and ITA No.308 of 2021 Madhucon Agra Jaipur Expressways Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ DB-A ‘ Bench, Hyderabad Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha, G. Accountant Member आ.अपी.सं /ITA Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Dy. Commissioner of Vs. Madhucon Agra Income Tax, Circle 16(2) Expressway Ltd Hyderabad Hyderabad PAN:AAECM4426F (Appellant) (Respondent) आ.अपी.सं /ITA No308/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2013-14) Mahu Bharartpur Vs. Dy. Commissioner of E…

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Madhucon Agra Jaipur Expressways Limited, Hyderabad

In the result, Revenue appeals for the A

ITA 286/HYD/2018[2014-15]Status: DisposedITAT Hyderabad02 Jun 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15)

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: Shri B Balakrishna, CIT (DR)
Section 43Section 43(1)

…ITA Nos 285 286 of 2018 and ITA No.308 of 2021 Madhucon Agra Jaipur Expressways Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ DB-A ‘ Bench, Hyderabad Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha, G. Accountant Member आ.अपी.सं /ITA Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Dy. Commissioner of Vs. Madhucon Agra Income Tax, Circle 16(2) Expressway Ltd Hyderabad Hyderabad PAN:AAECM4426F (Appellant) (Respondent) आ.अपी.सं /ITA No308/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2013-14) Mahu Bharartpur Vs. Dy. Commissioner of E…

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Madhucon Agra Jaipur Expressways Limited, Hyderabad

In the result, Revenue appeals for the A

ITA 285/HYD/2018[2013-14]Status: DisposedITAT Hyderabad02 Jun 2025AY 2013-14

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15)

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: Shri B Balakrishna, CIT (DR)
Section 43Section 43(1)

…ITA Nos 285 286 of 2018 and ITA No.308 of 2021 Madhucon Agra Jaipur Expressways Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ DB-A ‘ Bench, Hyderabad Before Shri Vijay Pal Rao, Vice-President A N D Shri Manjunatha, G. Accountant Member आ.अपी.सं /ITA Nos.285 & 286/Hyd/2018 (िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15) Dy. Commissioner of Vs. Madhucon Agra Income Tax, Circle 16(2) Expressway Ltd Hyderabad Hyderabad PAN:AAECM4426F (Appellant) (Respondent) आ.अपी.सं /ITA No308/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2013-14) Mahu Bharartpur Vs. Dy. Commissioner of E…

DCIT, Gurgaon vs. M/S. Motorola India Pvt. Ltd., Gurgaon

In the result, the appeal being ITA No

ITA 3646/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No.3641/DEL/2015 (Assessment Year: 2006-07) Motorola Solutions India Private Limited, vs. ACIT, (formerly known as Motorola India Pvt. Ltd.) Gurgaon Circle, 415/2, Sector 14, M.G. Road, Gurgaon. Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) ACIT, vs. Motorola Solutions India Private Limited, Gurgaon Circle, (formerly known as Motorola India Pvt. Ltd.) Gurgaon. 415/2, Sector 14, M.G. Road, Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) (APPELLANT) (RESPONDENT)…

Motorola Solutions India Pvt. Ltd., Gurgaon vs. ACIT, Gurgaon

In the result, the appeal being ITA No

ITA 3641/DEL/2015[2006-07]Status: DisposedITAT Delhi16 May 2025AY 2006-07

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No.3641/DEL/2015 (Assessment Year: 2006-07) Motorola Solutions India Private Limited, vs. ACIT, (formerly known as Motorola India Pvt. Ltd.) Gurgaon Circle, 415/2, Sector 14, M.G. Road, Gurgaon. Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) ACIT, vs. Motorola Solutions India Private Limited, Gurgaon Circle, (formerly known as Motorola India Pvt. Ltd.) Gurgaon. 415/2, Sector 14, M.G. Road, Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) (APPELLANT) (RESPONDENT)…

M/S. Motorola Solutions India Private Limited, Gurgaon vs. ACIT, Gurgaon

In the result, the appeal being ITA No

ITA 4789/DEL/2014[2005-06]Status: DisposedITAT Delhi16 May 2025AY 2005-06

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri G.C. Srivastava, AdvocateFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(3)Section 37(1)Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I’: NEW DELHI BEFORE SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No.3641/DEL/2015 (Assessment Year: 2006-07) Motorola Solutions India Private Limited, vs. ACIT, (formerly known as Motorola India Pvt. Ltd.) Gurgaon Circle, 415/2, Sector 14, M.G. Road, Gurgaon. Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) ACIT, vs. Motorola Solutions India Private Limited, Gurgaon Circle, (formerly known as Motorola India Pvt. Ltd.) Gurgaon. 415/2, Sector 14, M.G. Road, Gurgaon – 122 001 (Haryana). (PAN : AAACM9343D) (APPELLANT) (RESPONDENT)…

Deputy Commissioner of Income Tax, Circle 8 Pune, Pune vs. Alfa Laval India Pvt Ltd, Pune

In the result, the appeal of the Revenue is partly allowed

ITA 1723/PUN/2024[2017-18]Status: DisposedITAT Pune29 Apr 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1723/Pun/2024 Assessment Year : 2017-18

For Appellant: Shri H. AnandaFor Respondent: Shri Nikhil Pathak
Section 143Section 143(2)Section 143(3)Section 92C

…ternate judicial view that such provisions are entitled for deduction u/s 37 of the Act, as and when the provision is recognized. For this reliance can be placed on the decision of Hon'ble Supreme Court in case of Rotork Controls India (P.) Ltd. Vs CIT [2009] 314 ITR 62 (SC) wherein it was held: Section 37(1) of the Income-tax Act, 1961 Business expenditure- Allowability of Assessment years 1991-92 to 1994-95 Whether for a provision to qualify for recognition, there must be a present obligation arising from past events, settlement of which is expected to result in an outflow of resources and in respect of which…

DCIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4700/MUM/2013[2006-07]Status: DisposedITAT Mumbai21 Mar 2025AY 2006-07

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee’s own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon’ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon’ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settl…

DCIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4699/MUM/2013[2004-05]Status: DisposedITAT Mumbai21 Mar 2025AY 2004-05

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee’s own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon’ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon’ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settl…

Novartis India Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4574/MUM/2013[2006-07]Status: DisposedITAT Mumbai21 Mar 2025AY 2006-07

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee’s own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon’ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon’ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settl…

Novartis India Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 4573/MUM/2013[2004-05]Status: DisposedITAT Mumbai21 Mar 2025AY 2004-05

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee’s own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon’ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon’ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settl…

ACIT Cir 7(1), Mumbai vs. Novartis India Ltd, Mumbai

In the result, all the appeals of assessee and revenue and the cross

ITA 7799/MUM/2012[2007-08]Status: DisposedITAT Mumbai21 Mar 2025AY 2007-08

Bench: Justice (Retd.) C V Bhadang, Hon'Ble & Shri B R Baskaran, Hon'Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee's own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon'ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon'ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settle…

Novartis India Ltd, Mumbai vs. Asst CIT 7(1), Mumbai

In the result, all the appeals of assessee and revenue and the cross objections of the assessee are partly allowed in the aforesaid terms

ITA 7733/MUM/2012[2007-08]Status: DisposedITAT Mumbai21 Mar 2025AY 2007-08

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri B R Baskaran, Hon’Ble

For Appellant: Shri J D Mistry, Sr. AdvocateFor Respondent: Shri Kailash C Kanojiya, CIT-DR

…ordinate bench in the assessee’s own case in AY 2008-09 in ITA No.7644/Mum/2012 dated 28-09-2022. The co-ordinate bench has deleted the disallowance by following the decision rendered by the Hon’ble Supreme Court in the case of Rotork Controls India (P) Ltd (314 ITR 62)(SC), wherein the Hon’ble Supreme Court noticed that “a provision is a liability which can be measured only by using a substantial degree of estimation” and such provision can be allowed as deduction when (a) an enterprise has a present obligation as a result of past event (b) it is possible that an outflow of resources will be required to settl…

Deputy Commissinoer of Income Tax, Chennai vs. Cholamandalam Ms General Insurance Company Limited, Chennai

ITA 470/CHNY/2024[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca Department By Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement 19.03.2025

Section 115JSection 14ASection 2Section 37(1)

…e above claim is not supported by the actual valuation and hence, he disallowed ₹148,43, 01,915/-. The Id 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…