https://www.taxtmi.com/caselaws?id=797565 Actuarially backed ad hoc contributions made to remedy an established deficit in an approved superannuation fund are distinguished from ordinary annual contributions and initial contributions. Their legal character depends on their deficit-remedying purpose, including liabilities arising from earlier funding constraints, rather than the period over which the deficit arose. The annual ceiling under Rule 87 does not apply to such actuarially necessary funding, as applying it could impair fund solvency and conflict with the deduction available for contributions to approved funds under section 36(1)(iv). A reasoned application of governing precedents supports deletion of a disallowance and does not render that determination arbitrary or perverse. en-us Fri, 21 Aug 2026 00:00:00 +0530 Mon, 24 Aug 2026 08:33:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797565 Actuarially backed ad hoc contributions made to remedy an established deficit in an approved superannuation fund are distinguished from ordinary annual contributions and initial contributions. Their legal character depends on their deficit-remedying purpose, including liabilities arising from earlier funding constraints, rather than the period over which the deficit arose. The annual ceiling under Rule 87 does not apply to such actuarially necessary funding, as applying it could impair fund solvency and conflict with the deduction available for contributions to approved funds under section 36(1)(iv). A reasoned application of governing precedents supports deletion of a disallowance and does not render that determination arbitrary or perverse. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797565