COMMNR. OF INCOME TAX, UDAIPUR vs MCDOWELL & CO. LTD.

The Supreme Court addressed the applicability of Section 43B of the Income Tax Act, 1961, determining that unpaid bottling fees, secured by a bank guarantee, do not qualify as actual payment for deduction purposes under Section 43B if not paid before the return filing deadline under Section 139(1). The Court also remitted the matter regarding the nature of capital expenditure for new transformers back to the Assessing Officer for further consideration, referencing the principles established in Commissioner of Income Tax v. Saravana Spinning Mills and Commissioner of Income Tax v. Ramaraju Surgical Cotton Mills. The appeal was disposed of accordingly.