Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
The assessee bank made provisions for group gratuity and leave encashment by debiting expenses in its books, but these provisions were never treated as real expenses for income tax purposes. The AO made additions for the difference between the book provisions and actuarial valuations. The ITAT held that the expenses debited pertained to the assessment year and were real expenses, not provisions. The AO's findings that the amounts did not pertain to the year were perverse. Only real income is taxable, not provisions, as held in Shoorji Vallabhdas case. The assessee did not claim notional expenses to reduce profits. The AO's additions were deleted.
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