Tax Consultant Invoice Charges Recognized in Current Year, Not Prior Period, When Invoice is Issued.

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....Prior period expenditure - Addition of legal and professional charges - if the Tax Consultant following its general practice raises the invoice upon conclusion of the matter after passing of the order by the concerned authority, we are of the considered view that such expenditure cannot be treated as prior period expenses. Particularly, it is only when the invoices for legal and professional services are raised by the Consultant, the liability arises / crystallizes in the hands of the assessee and it is only in that year such expenditure will be allowable to the assessee - AT....