Accrued business liability requires certainty: estimated access charge provision was disallowed as an unascertained expense.

A mere estimate for access charges was not deductible as an accrued and ascertained business liability because the exact obligation and identifiable payees were not established with certainty. The Tribunal treated the provision as an unascertained liability, noted the assessee's inconsistent position on the deduction and tax deduction at source, and distinguished the authorities relied on as factually different. The disallowance was upheld.

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Issues: Whether the provision made for access charges was an allowable deduction as an accrued and ascertained business liability, and whether the disallowance was justified for want of tax deduction at source.

Analysis: The assessee claimed deduction for a provision created on estimate basis under the matching concept, contending that the liability had accrued though invoices were not received. The provision was not treated as allowable because the amount was only an estimate, the exact liability and the identifiable recipients were not shown with certainty, and the assessee itself took inconsistent stands on allowance of the provision and applicability of tax deduction at source. The Tribunal held that a mere provision for an unascertained liability does not satisfy the requirements for deduction, and the cited authorities on accrued liability were distinguishable on facts.

Conclusion: The provision for access charges was not allowable as deduction, and the disallowance was upheld.

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