Year-end provisions for audit fees and contractor payments...

Year-end provisions for audit fees and contractor payments remain deductible where consistently accrued, discharged subsequently, and excess provisions are reversed and offered to tax. Unclaimed interest or capital expenditure recorded in the balance sheet cannot be added merely because it appears as an accrued liability. Section 251 permits remand or setting aside only for ex parte assessments under section 144, making remand for fresh verification impermissible for assessments under section 143(3). No disallowance arises for payments not subject to tax deduction at source or for expenditure relating to exempt income where no exempt income is earned. Income already offered to tax cannot be taxed again; actuarially valued leave-encashment liabilities are deductible; and under-reporting penalty requires valid initiation with recorded satisfaction.