Actuarial liability allowed

In a detailed and principle driven ruling, the Tribunal reaffirmed that actuarial valuation converts future employee benefit obligations into present, scientifically determinable liabilities. 

It rejected the Revenue’s attempt to deny deduction on the ground that specific provisions under Section 36 override Section 37, clarifying that pension provisioning (distinct from fund contributions) falls outside the restrictive framework of Sections 36 and 40A. 

The Tribunal further held that absence of immediate payment does not affect deductibility under the mercantile system and that actuarial valuation is a recognised method to quantify accrued obligations. 

The decision also reinforces the doctrine of consistency, emphasizing that identical claims allowed in earlier years cannot be arbitrarily disallowed without change in facts or law.