FUJI ELECTRIC INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI
In the result the appeal of the Assessee is partly allowed for statistical purposes
ITA 701/CHNY/2025[2020-21]Status: DisposedITAT Chennai01 Dec 2025AY 2020-21
Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha
For Appellant: Shri. Siddhesh Chaugula, C.AFor Respondent: Shri. A R V Sreenivasan, C.I.T
Section 92C
transfer pricing adjustment of Rs.7,96,238/- is allowed.
9. The Assessee has created two provisions in the year end viz.,
1) Provision for Installation and Authorised services: Rs.65,50,563/- and 2) Provision for Sales Commission: Rs.1,85,56,926/-.
10. In the Draft Assessment Order, the AO has disallowed the same on the ground that provision
