Apparent Mistake vs. Debatable Issue – ITAT Protects Assessee from Unwarranted 154 Action

QLAR India Private Limited Vs DCIT (ITAT Kolkata) Background Qlar India Pvt. Ltd., a Bengaluru-based manufacturer of plant sequencing, batching & weighing systems, filed its return of income belatedly for AY 2014-15 declaring income of ₹11.91 crore. The assessment was completed u/s 143(3) on 29.12.2016, wherein AO examined the issue of provision for warranty & made no disallowance. Subsequently, the AO invoked rectification proceedings u/s 154 on 17.09.2019 & disallowed warranty provision of ₹1.27 crore, holding it not allowable under Section 37(1). CIT(A)’s Order Assessee ch...