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2018 (5) TMI 1574 - AT - Income TaxDisallowance made on account of management training expenses paid to MBA Graduates - allowable busniss expenditure - Held that:- Once profit/income is determined, it is immaterial whether that income is offered for tax under the head "Income from business" or "Income from other sources". As held in the case of United Commercial Bank Ltd. v. CIT [1957 (5) TMI 11 - SUPREME COURT] held that the business income is broken up under different heads only for the purpose of computation of the total income; by that break up the income does not cease to be the income of the business, the different heads of income being only the classification prescribed by the Act for computation of income. The genuineness of impugned expenditure was not in doubt. The expenditure incurred wholly and exclusively for the purpose of business was allowable. Therefore, the assessee was entitled to deduction of salary expenses in question. Disallowance u/s 43B - service tax liability - Held that:- Since these fees were not received by the assessee, naturally service tax liability also did not accrue as per the provision of section 6 of the service tax act hence not disallowable under section 43 B of the Act. Even otherwise disallowance under Section 43B was not warranted in this case, as Service Tax was not claimed as an expenditure, neither it stood debited to the P&L Account by the assessee
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