https://www.taxtmi.com/caselaws?id=433031 Tax deduction at source was not attracted on a year-end provision for legal and professional charges where the payees were not identified, the amount had not been ascertained, and the entry was reversed at the start of the next year. The court applied the principle that TDS arises only when income is attributable to a definite recipient; a mere book entry, without accrued income to a known payee, does not trigger the deduction obligation. The Revenue's relied-on authority was distinguished because it involved identified payees, and earlier Karnataka decisions on similar year-end provisions were followed. The disallowance for failure to deduct tax at source was therefore not sustainable. en-us Thu, 22 Dec 2022 00:00:00 +0530 Mon, 10 Nov 2025 11:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=433031 Tax deduction at source was not attracted on a year-end provision for legal and professional charges where the payees were not identified, the amount had not been ascertained, and the entry was reversed at the start of the next year. The court applied the principle that TDS arises only when income is attributable to a definite recipient; a mere book entry, without accrued income to a known payee, does not trigger the deduction obligation. The Revenue's relied-on authority was distinguished because it involved identified payees, and earlier Karnataka decisions on similar year-end provisions were followed. The disallowance for failure to deduct tax at source was therefore not sustainable. Case-Laws Income Tax Thu, 22 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=433031