Why Some Expenses Are Allowed Only On A Payment Basis Under Accrual Accounting



Quick Summary
While accrual accounting recognises income and expenses when they occur, tax law sometimes requires actual payment before a deduction is allowed. This is particularly true for statutory liabilities and employee-related dues, as highlighted by Section 43B of the Income-tax Act. The law aims to prevent taxpayers from claiming deductions for expenses they haven't yet paid, especially when public obligations or employee welfare are involved, ensuring that tax benefits follow genuine economic responsibility.

1. Accounting Profit vs Taxable Income - Judicial Recognition of the Divide One of the most fundamental yet frequently misunderstood principles of income taxation is that profit as per the books of account is not necessarily equivalent to taxable income. While commercial accounting aims to evaluate
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FAQ :

Accounting profit aims to evaluate business performance over a period, while taxable income is determined by the Income-tax Act to calculate legally taxable income, which can differ from accounting outcomes.

Accrual accounting recognises income and expenditure when they accrue, rather than when they are actually received or paid, providing a better reflection of economic reality for ongoing businesses.

Section 43B was introduced to curb the practice of taxpayers claiming deductions for statutory liabilities based on book entries while postponing actual payment, linking deductions to actual payment.

Employee contributions to PF and ESI are considered held in trust by the employer and are not merely business expenses. Delaying their deposit constitutes a breach of statutory obligation, and deduction is linked to actual payment.

No, Section 43B does not convert the mercantile system to a cash system. It merely postpones the allowability of a deduction until actual payment, while the accounting method itself remains accrual-based.

Ordinary commercial expenses like rent, professional fees, and utilities are generally allowed on an accrual basis once the liability has crystallised and is reasonably ascertainable.


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About the Author

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CA. Raj Jaggi is a Chartered Accountant based in New Delhi, primarily practising in the field of Goods and Services Tax (GST) consultancy, litigation support, and advisory services. After being associated with the leading indirect tax firm A.K. Batra and Associates for nearly 19 years, from June 2007 to March 2026, he ... Read more

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