No disallowance of quantified liabilities, documented payments & reconciled books on a purely ad hoc basis

CIE Automotive India Limited Vs DCIT (ITAT Mumbai) Conclusion: Provisions that were typically restricted or viewed as contingent become fully deductible business expenses the moment they were quantified, crystallized, and physically paid out before the tax return filing deadline. Revenue could not arbitrarily disallow a flat percentage of direct operational or employee welfare expenses based on general suspicion. To sustain a disallowance, the AO must identify specific non-business items or formally invalidate the books of account. Merely listing newly acquired assets on a balance sheet or aud...