Shanti Prime Publication Pvt. Ltd.
Section 37(1) read with section 263 of the Income Tax Act, 1961 — Business Expenditure — Assessee company made a provision for expenditure towards copper concentrate purchase on basis of provisional and when final amount was realised at end of the year ,difference in provision made by assessee and final amount of purchase was adjusted in credit or debit side of profit and loss account accordingly. Since above provision was made on basis of London Metal Exchange prices for copper concentrate and such provision was certified by auditors as well as approved by shareholders of company, same could not be disallowed during year by invoking section 263 on grounds of same being contingent —Vedanta Ltd. vs. Assistant Commissioner of income tax [2020] 180 ITD 8 (Delhi-trib)