https://www.taxtmi.com/caselaws?id=78744 The dispute concerned whether a tribunal could direct that payments to expatriate employees be deducted in a year different from the year of payment. The court affirmed that the tribunal lacked jurisdiction to grant deductions for assessment years other than the year of actual payment; the legal principle of commercial expediency, if available, applies in the year of payment only. Tax authorities disallowed claims for earlier years on the basis that the liability was contingent and unascertained and payments were not supported by any enforceable contractual obligation. The tribunal's factual finding of absence of contractual liability and the limitation on jurisdiction were upheld and the appeal dismissed. en-us Tue, 14 Sep 2010 00:00:00 +0530 Sat, 14 Feb 2026 10:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78744 The dispute concerned whether a tribunal could direct that payments to expatriate employees be deducted in a year different from the year of payment. The court affirmed that the tribunal lacked jurisdiction to grant deductions for assessment years other than the year of actual payment; the legal principle of commercial expediency, if available, applies in the year of payment only. Tax authorities disallowed claims for earlier years on the basis that the liability was contingent and unascertained and payments were not supported by any enforceable contractual obligation. The tribunal's factual finding of absence of contractual liability and the limitation on jurisdiction were upheld and the appeal dismissed. Case-Laws Income Tax Tue, 14 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78744