Provisions not backed by any actual expenditure cannot be allowed as deduction

DCIT Vs Dia Vikas Capital Pvt. Ltd. (ITAT Delhi)

On going through the above details from the assessee’s ledger account, it is seen that sum of Rs. 80,00,000/- is a provision made on 31.12.2008 against the consultancy fees. Similarly there is another item of Rs. 84,50,000/- which is again a provision for consultancy fee. This transaction is also dated 31.12.2008. There can be no doubt about the allowing of deduction in respect of expenses actually incurred for due diligence. If there is only a provision not backed by any actual expenditure, then such a provision cannot be allowed

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