Havells India Ltd. v. ACIT (LTU) (2023)101 ITR 81 (Delhi) (Trib)

S. 37(1) : Business expenditure-Provision for scheme not contingent-Made on scientific basis-Own orders in earlier years-No contrary findings-Addition to be deleted.

Held, that an identical issue with regard to the sales incentive payable-under the Shahenshah Scheme arose in the assessee’s own case for earlier-AY.s, before the Tribunal, which had decided the issue in favour of the assessee by pointing out that the provision for the scheme was made on scientific basis. In the year under consideration also, the Revenue had not produced any new material to bring out any distinguishing feature to show otherwise. The addition was not justified. (AY. 2014-15).