https://www.taxtmi.com/caselaws?id=793544 Year-end provisions for identified resident professional services were treated as attracting TDS when the liability crystallised and the amount payable was ascertainable, so disallowance under section 40(a)(ia) was justified where tax was not deducted at that stage. Where tax was deducted and deposited on or before the due date for filing the return, the corresponding expenditure remained allowable in that year; where deposit was made later, the expenditure was allowable in the year of actual payment. Payments to offshore lawyers required fresh examination under section 195 and the applicable treaty on chargeability and residency. A reversed provision for Sapphire Professional Services was treated as an unascertained liability and sustained as disallowable. en-us Mon, 15 Jun 2026 00:00:00 +0530 Thu, 18 Jun 2026 08:45:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793544 Year-end provisions for identified resident professional services were treated as attracting TDS when the liability crystallised and the amount payable was ascertainable, so disallowance under section 40(a)(ia) was justified where tax was not deducted at that stage. Where tax was deducted and deposited on or before the due date for filing the return, the corresponding expenditure remained allowable in that year; where deposit was made later, the expenditure was allowable in the year of actual payment. Payments to offshore lawyers required fresh examination under section 195 and the applicable treaty on chargeability and residency. A reversed provision for Sapphire Professional Services was treated as an unascertained liability and sustained as disallowable. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793544