JUDGMENT :

G.S. Kulkarni, J.

1. Rule, made returnable forthwith. Heard finally by consent of the parties. These are three petitions filed by the petitioner/assessee, assailing the orders passed by the Principal Commissioner of Income Tax under Section 264 of the Income Tax Act, 1961 (for short ‘the Act’), whereby the petitioners’ revision applications filed against the intimation under Section 143(1) of the Act for the Assessment Years 2019-20, 2020-21 and 2021-22 are rejected. As the issues of law and fact are common except for the amounts being different, the petitions are being disposed of by this common judgment.

2. Writ Petition no.2664 of 2024 which is for the Assessment year 2019-20 is argued as the lead matter, hence, we refer to the facts of the said case.

3. The petitioner filed its return of income for the Assessment year 2019-20 declaring income of Rs.1,89,71,207/-. It is the petitioner’s case that the petitioner was making a provision for bonus, ex-gratia and incentives (collectively referred as ‘bonus’) payable to employees, at the time of preparation of the financial statements. It is stated that the actual payment was dependent on various factors, and on an aggregate ba