Section 40(a)(ia) applies to transaction made during the year

In the result, we are of the opinion that Section 40(a) (ia) would cover not only to the amounts which are payable as on 31^th March of a particular year but also which are payable at any time during the year. Of course, as long as the other requirements of the said provision exist. In that context, in our opinion the decision of the Special Bench of the Tribunal in the case of M/s. Merilyn Shipping & Transports vs. ACIT (surpa), does not lay down correct law.

IN THE HIGH COURT

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