The High Court's decision addressed several key issues regarding ...

Tax dispute: Royalties to AEs justified, stock valuation method upheld, warranty claims addition deleted, CSR expenses allowed.

Case Laws     Income Tax

October 18, 2024

The High Court's decision addressed several key issues regarding the assessee's tax assessment. Firstly, it upheld the Tribunal's finding that the royalty paid by the assessee to its Associated Enterprises (AEs) was justified as the AEs were manufacturing sub-contractors, and the assessee had been granted licenses for patents, know-how, and trademarks. Secondly, it affirmed the assessee's valuation of closing stock based on cost or net realizable value, whichever is lower, as a consistently followed and accepted method. Thirdly, it upheld the Tribunal's deletion of the Assessing Officer's (AO) addition related to excess provision for claims against warranties, as the AO failed to adequately justify the addition. Fourthly, it rejected the Revenue's contention to exclude Corporate Social Responsibility (CSR) expenses from book profits u/s 115JB, finding no statutory basis for such exclusion. The High Court concluded that no substantial questions of law arose from the Tribunal's decision on these issues.

View Source