Held that neither the Assessing Officer nor Commissioner (Appeals) had examined the details filed before them during the set aside assessment proceedings or even remand proceedings by the Assessing Officer. They had simply noted that the assessee could not establish that all the conditions prescribed in the decision of the Supreme Court in Rotork Controls India Pvt. Ltd v.CIT (2009) 314 ITR 62 (SC) were satisfied. Even now, the assessee had not produced before the Assessing Officer or the Commissioner (Appeals) as to how the provision was based on historical trend and a reliable estimate as held by the Supreme Court. The assessee had filed the details before the Tribunal and accordingly, the matter  was remanded for  fresh verification. (AY. 2011-12 to 2013-14)