Applicability of ICDS: timing of TDS entries determines whether expenditure is disallowable under TDS disallowance provisions.

ICDS apply only to computation of income under Profit & gains from business or profession and Income from Other Sources. For Sections 40(a)(i) and 40(a)(ia), disallowance depends on whether tax was deductible and whether an entry creating that liability or deduction existed in the year expenditure was claimed; absence of such an entry negates disallowance, while prior-year deduction of tax prevents disallowance in the year of allowance.

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