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Issues involved: Interpretation of provision for warranty claims by a new company u/s 263 of the Income Tax Act, 1961.
The judgment pertains to a case where the Assessee, a new company manufacturing engines for vehicles, estimated warranty claims and made a provision of &8377; 16,56,404. The Assessing Officer initially accepted this claim, but the Commissioner of Income Tax (CIT) u/s 263 set aside the order, stating that there was no basis for the Assessee to make such a claim. The Tribunal, however, overturned the CIT's decision, emphasizing that the warranty clause was a part of the sale documents and could be ascertained based on certain parameters, including the Assessee's sales during the year. The Tribunal also cited the decision in Bharat Earth Movers Ltd. v. Commissioner of Income Tax, [2000] 245 ITR 428, to support its conclusion. The key issue revolved around whether a new company like the Assessee could reasonably estimate warranty claims despite lacking past experience in this regard. The Assessing Officer initially accepted the provision made by the Assessee, but the CIT u/s 263 disagreed, leading to a legal dispute. The Tribunal ultimately sided with the Assessee, highlighting that the warranty clause was a valid liability based on sales documents and could be quantified using specific parameters, thereby justifying the Assessee's provision for warranty claims. In its decision, the High Court upheld the Tribunal's ruling, stating that the Tribunal did not err in its interpretation. The Court found no merit in the Revenue's appeal and consequently dismissed it.
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