CIT v. Rane Trw Steering Systems Ltd. (2020)423 ITR 291 (Mad) (HC)

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Provision for warranty – Revision order is held to be not valid .[ S.143(3) ]

Dismissing the appeal of the revenue the Court held that ,the provision made on the basis of turnover on the same or similar percentage year after year followed a rationale and scientific method of making a provision for such warranty. The actual claims made by customers against such warranty provision could not be the sole criteria, to be labelled as the scientific method. It was the consistency and the commercial prudence of the assessee, in which the assessee chose to make a provision for warranty based on its total turnover figure, which could not be said to be unscientific, by any stretch of imagination. Such decisions, taken in normal commercial prudence, could not be interfered with or superseded by the tax authorities. The Tribunal was perfectly justified in holding that the revisional proceedings in such circumstances were not justified.( AY.2004-05)