Set-off of Sales Tax as Deemed Payment u/s 43B: Deductible as Actual Payment Through Legal Fiction.

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....Sales tax set off as deduction u/s 43B - whether the set off or adjustment amounts to deemed payment? - When the assessee purchases raw materials, it is liable to pay purchase tax on the purchase. An equivalent of this amount is adjusted towards the liability on the sale of the product produced out of the raw materials purchased. This adjustment, by legal fiction, is deemed to be an actual payment of the tax liability. Admittedly, this amount is a tax payable. If it is a tax liability on being set off or adjusted, deemed actual payment by legal fiction, it is deductible under Section 43B of the Act. - HC....