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Write-backs of employee benefit provisions are taxable only where the corresponding expenditure was allowed as a deduction in an earlier year; otherwise, taxing the reversal would result in double taxation. Taxability requires giving effect to final appellate treatment of the original provision. Interest on excess refunds under section 234D is consequential and must be recomputed against the final assessment position; where a refund follows the original assessment, the levy may be restricted to the applicable one-month period. Refunds adjusted against outstanding tax demands must first be appropriated towards interest payable under section 244A and then towards principal tax.
Write-backs of employee benefit provisions are taxable only where the corresponding expenditure was allowed as a deduction in an earlier year; otherwise, taxing the reversal would result in double taxation. Taxability requires giving effect to final appellate treatment of the original provision. Interest on excess refunds under section 234D is consequential and must be recomputed against the final assessment position; where a refund follows the original assessment, the levy may be restricted to the applicable one-month period. Refunds adjusted against outstanding tax demands must first be appropriated towards interest payable under section 244A and then towards principal tax.
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