Pure reimbursement of common legal and professional expenditure,...

Pure reimbursement of common legal and professional expenditure, without an income element in the recipient association's recovery, does not attract tax deduction at source; accounting labels do not determine the payment's true character. The related disallowance was deleted because the association had apportioned actual member costs and had deducted tax when paying legal professionals. Where tax was deducted and deposited subsequently on professional-fee payments, the expenditure was not allowable in the relevant year but could be claimed in the subsequent year subject to statutory verification. Year-end provisions require party-wise evidence showing that each liability was ascertained, accrued and incurred for business purposes; the provision issue was remanded for fresh examination.