The Tribunal held that the Commissioner (Appeals) had found that the assessee had made provision for a huge amount and had reversed such provision in the subsequent years without the utilization of the amount for providing warranty obligation. Hence it was clear that the provision made in the books of account for warranty obligation was not on the basis of systematic estimation of liability based on past experience and future obligation. Therefore, the provision made in the books of account for warranty obligation was an unascertained liability and contingent in nature. It could not be allowed as a deduction. (AY. 2011-12 to 2014-15)
BGR Energy Systems Ltd. v. ACIT (2022) 96 ITR 625 (Chennai) (Trib)
S. 37(1) : Business expenditure-Accrued or Contingent Liability-Provision for warranty-Ad-hoc basis-Not deductible.