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of <h1>Clarification on Section 40(a)(ia): Applies to All Payable Amounts, Not Just Year-End Balances, per Income-tax Act.</h1> The circular addresses conflicting judicial interpretations regarding Section 40(a)(ia) of the Income-tax Act, 1961, which concerns amounts not deductible in computing business income if tax is not deducted at source. While some judicial authorities, like the Special Bench of ITAT Vishakhapatnam and Allahabad High Court, held that the provision applies only to amounts payable at the year's end, others like the Calcutta and Gujarat High Courts ruled it covers amounts payable anytime during the year. The Board clarifies that Section 40(a)(ia) applies to all amounts payable throughout the year, not just those outstanding at year-end. If a High Court ruling contradicts this view, it should be reported for potential Supreme Court appeal or legislative amendment.
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