9911796707
TMI Blog2017 (11) TMI 1313X X X X Extracts X X X X X X X X Extracts X X X X ..... is delayed. Therefore this appeal of revenue is dismissed and additon made by AO of ₹ 21,35,45,197/- on account of royalty paid to SEC Korea is deleted. Deletion of Addition made by AO on account of Provision of Warranty/After Sale Service Compensation- Held That:- CIT(A) delete the addition done by AO on grounds that AO has done the same on Adhoc basis but basis the factual findings the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bunal ( ITAT ) in ITA No. 2261/Del/2009 for the Assessment Year ( AY ) 2003-04. 4. It is pointed out by learned counsel for the Appellant-Revenue that barring questions relating to royalty and warranty , the other questions that sought to be urged in this appeal stands answered against the Revenue and in favour of the Assessee by this Court by its order dated 18th April 2017 in Revenue s app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 29,80,741 made by the AO on account of provision of warranty/after sale service compensation, it is seen that CIT (A) disagreed with the AO that the said provision was made on ad hoc basis. The CIT (A) has returned a factual finding that the provision was made on scientific basis. 7. Consequently, this issue too does not give rise to a substantial question of law. 8. Accordingly, the appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X
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