SEBI registration fee deduction on actual payment basis under section 43B upheld, with no substantial question of law arising.

SEBI registration fee paid under a regularisation scheme was treated as an allowable deduction on actual payment basis under section 43B of the Income-tax Act because the amount was paid during the relevant year and fell within the statutory scheme for specified dues. The Tribunal's allowance of the deduction was held to be consistent with the provision and the applicable departmental circular, and no substantial question of law arose for interference.

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Issues: Whether the SEBI registration fee paid under the regularisation scheme was allowable as a deduction under section 43B of the Income-tax Act, 1961 on actual payment basis, and whether any substantial question of law arose.

Analysis: The payment was made pursuant to the SEBI regularisation scheme and represented a fee connected with the assessee's regulatory liability as a broker. Section 43B permits deduction of specified statutory dues, including fee, only on actual payment. The Court found that the amount had been paid during the relevant year and that the Tribunal's view allowing the deduction was consistent with the statutory scheme and the departmental circular governing such payments. On these facts, no substantial question of law arose for interference.

Conclusion: The deduction was rightly allowed under section 43B, and the Revenue's appeal failed.

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