Prior period expense crystallisation, ESOP discount deduction, and demerger loss carry forward turned on evidence and strict statutory compliance.

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....Prior period expenses are deductible only if the liability crystallised in the relevant year and is supported by evidence; the Tribunal remitted the disallowance for fresh verification. ESOP discount was treated as employee remuneration incurred wholly and exclusively for business, so the deduction was allowed and the disallowance deleted. The demerger loss and depreciation claim failed because the statutory conditions for the resulting company were construed strictly and the required share issuance was not satisfied, so carry forward and set-off were denied. Deferred income recognised under the assessee's consistent accounting method was upheld, as earlier orders in its own case remained binding.....