2013 (8) TMI 558

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....gment of the Income Tax Appellate Tribunal (hereinafter referred to as 'the Tribunal') dated August 31, 2012. The following questions, besides other, have been presented for our consideration :      "(i) Whether in the facts and circumstances of the case and in law, the Appellate Tribunal is justified in holding that the provisions of section 40(a)(ia) of the Act applies onl....

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....008, held that section 40(a)(ia) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), would apply only to the expenditure which is payable as on 31st March of the year under consideration and not to the expenditure which had already been paid during the year itself. 3. We are of the opinion that the ratio requires a serious consideration. Also being an issue of recurring nature, ....