Crystallised corporate guarantee liability remains deductible in the year of settlement despite later discharge through consent terms.

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....Corporate guarantee liability becomes deductible in the previous year in which settlement fixes and crystallises the obligation. Where the settlement occurred in the previous year relevant to Assessment Year 1998-99, subsequent consent terms merely implemented and discharged the already determined liability; they did not defer the year of deduction. The resulting business-loss deduction was therefore allowable for Assessment Year 1998-99.....