Section 43B of the Income-tax Act, 1961 has always been considered a cornerstone provision that prevents misuse of deduction claims by ensuring that certain liabilities are allowed only when actually discharged. Over the years, it has acted as a deterrent against claiming notional expenses that do not result in actual outflow of resources. Until recently, its scope was largely restricted to statutory payments, contributions, and certain financial obligations.
The Finance Act, 2023 changed the traditional understanding of this provision by inserting clause (h). This amendment is specifically designed to strengthen the position of micro and small enterprises by tying deductibility of payments to the timelines prescribed under the Micro, Small and Medium Enterprises Development Act, 2006. This represents a major intersection of commercial law and taxation, where fiscal provisions are used to enforce contractual and statutory discipline.
We explored the evolution of Section 43B, the introduction of clause (h), its relationship with the MSMED Act, the notifications issued by the Central Board of Direct Taxes, and the wider implications for businesses and auditors.
Evolution of Section 43B
When Section 43B was introduced, the objective was to tackle the practice of businesses claiming deductions for expenses that were never actually paid. For example, statutory dues such as excise duty, customs duty, and other levies were often accounted as expenses but carried forward without timely payment. This led to a mismatch between the accounting profits and taxable income.
To address this, Section 43B stipulated that deductions for certain specified expenses would be permitted only in the year in which actual payment was made. Initially, the provision covered taxes, duties, and employee-related contributions. Over the years, successive amendments expanded its reach to include interest on loans from public financial institutions, interest on loans from scheduled banks, and leave encashment liabilities.
The philosophy underlying Section 43B remained constant: no deduction should be available unless there is actual discharge of the liability. However, one consistent feature was the relaxation provided to taxpayers that allowed payments made up to the due date of filing of the return of income to still qualify for deduction in the year of accrual. This relief provided flexibility without undermining the intent of the law.
Introduction of Clause (h) by Finance Act, 2023
The Finance Act, 2023 inserted clause (h) into Section 43B, effective from assessment year 2024-25. This clause covers amounts payable to micro and small enterprises. It disallows deductions unless payments are made within the time limits specified under Section 15 of the MSMED Act, 2006.
This amendment significantly alters the scheme of Section 43B. Unlike other clauses where the cut-off is the due date of filing the return under Section 139(1), clause (h) ties deductibility strictly to the contractual and statutory deadlines under the MSMED Act. If a buyer fails to settle dues within the specified time, the deduction for such expenditure is permanently disallowed in that year, even if the payment is later made before filing of the return.
This stricter framework underlines the seriousness with which the legislature views delayed payments to micro and small enterprises. It also creates a strong financial disincentive for businesses that habitually delay payments, thereby encouraging better liquidity for smaller entities.
MSMED Act, 2006 and Its Relevance
The MSMED Act was enacted to promote the growth and development of micro, small, and medium enterprises. One of its most important provisions is the obligation it places on buyers to make timely payments to suppliers.
Section 15 of the Act provides that payments to MSE suppliers must be made on or before the date agreed upon in writing. If there is no written agreement, payment must be made within 15 days of acceptance or deemed acceptance of goods or services. However, the agreed period cannot exceed 45 days in any case.
Section 16 of the Act imposes liability on the buyer to pay compound interest with monthly rests at three times the bank rate notified by the Reserve Bank of India for any delay beyond the permitted period. Section 23 further clarifies that this interest is not allowable as a deduction for the purpose of computing income under the Income-tax Act.
By aligning Section 43B(h) with Section 15 of the MSMED Act, the government has essentially created a tax-based enforcement mechanism. Now, failure to pay within the statutory period not only attracts interest but also leads to disallowance of the principal amount itself for income-tax purposes.
Legislative Rationale for Clause (h)
The government has long recognized that delayed payments to MSEs are a chronic issue in the Indian economy. These enterprises often operate with thin working capital and rely on prompt payments to sustain operations. While the MSMED Act already provided for mandatory interest on delays, enforcement was weak because smaller suppliers were often reluctant to pursue legal remedies against larger buyers for fear of losing business relationships.
The introduction of Section 43B(h) changes the dynamic by shifting responsibility to the tax framework. Larger businesses now face tax consequences for non-compliance, irrespective of whether the supplier raises a dispute or not. This creates a systemic safeguard for timely payments.
Another important aspect is the government’s broader policy objective. Strengthening the MSE sector contributes to employment generation, industrial growth, and inclusive development. By embedding the payment discipline into the tax system, the government reinforces its policy goals without creating an additional regulatory burden.
Initial Notification Amending Form 3CD
The effectiveness of Section 43B(h) depends on transparent reporting. For this purpose, the Central Board of Direct Taxes issued Notification G.S.R. 155(E) on 5 March 2024 to amend Form 3CD. This form, which contains particulars required to be furnished under Section 44AB, is the basis of tax audit reporting.
The notification attempted to include clause (h) within Clause 26 of Form 3CD, which already dealt with disallowances under Section 43B(a) to (g). However, this approach immediately raised concerns. The reporting under Clause 26 was structured around the due date of filing of return, whereas Section 43B(h) is tied to the timelines specified in the MSMED Act. This created a mismatch and risked underreporting or misreporting of delayed payments to MSEs.
Corrigendum Notification and Shift to Clause 22
To resolve the inconsistency, the CBDT issued another notification G.S.R. 223(E) on 19 March 2024. This corrigendum removed the earlier amendment to Clause 26 and instead modified Clause 22 of Form 3CD.
Prior to this change, Clause 22 required reporting of interest payable under Section 16 of the MSMED Act. After the amendment, its scope was expanded to cover two aspects: principal amounts disallowable under Section 43B(h) and interest on delayed payments that are inadmissible under Section 23 of the MSMED Act.
This adjustment ensured that delayed payments to MSEs are comprehensively reported in one clause, with clear distinction between principal and interest. Clause 26 continues to apply to the other items under Section 43B, while Clause 22 is exclusively dedicated to MSE-related disallowances.
Implications for Businesses
The corrigendum has significant implications for businesses of all sizes. First, companies must now strengthen their vendor identification systems to distinguish between micro, small, and medium suppliers. This involves obtaining Udyam registration details and updating vendor masters accordingly. Payments to medium enterprises are not covered under Section 43B(h), but micro and small enterprises must be carefully monitored.
Second, businesses must adjust their accounts payable processes to ensure compliance with Section 15 timelines. It is no longer sufficient to clear outstanding dues before the return filing date to claim deductions. The payment discipline must be integrated into operational practices.
Third, companies should review their year-end provisions. Any outstanding dues to MSEs as of 31 March that have crossed the permissible timeline under the MSMED Act will be disallowed in computing taxable income. This can impact the effective tax rate and financial reporting.
Implications for Auditors
Auditors play a central role in implementing these provisions. Under Clause 22 of Form 3CD, they are required to report disallowable principal amounts and inadmissible interest. Unlike mechanical reporting of overdue balances, this responsibility requires auditors to form a considered opinion on whether an item qualifies as disallowable under Section 43B(h).
Auditors must ensure that only amounts otherwise allowable under sections such as 30 to 37(1) are reported. Items already disallowed under other provisions like Section 37(1), Section 40, or Section 40A do not need to be duplicated. They must also verify the management’s process of identifying MSE suppliers, cross-check Udyam registrations, and ensure that engagement letters clearly allocate responsibility for classification of vendors.
The auditor’s task is not limited to identifying delays; it involves ensuring that the reporting is accurate, complete, and consistent with the legislative intent.
Broader Impact on the MSME Ecosystem
Section 43B(h) has the potential to transform the payment culture in India. For MSEs, the provision ensures that buyers are strongly incentivized to pay on time. The risk of tax disallowance adds a powerful layer of enforcement, which could improve cash flows and reduce dependency on working capital finance.
For larger businesses, this provision requires a shift in mindset. Timely settlement of dues is no longer just a matter of good governance but a statutory necessity with tax implications. It promotes fairness in commercial dealings and strengthens business relationships built on trust.
At a macroeconomic level, this provision aligns with the government’s vision of making the economy more resilient and inclusive by empowering smaller enterprises. It also enhances transparency in tax audits and reduces opportunities for manipulating payment schedules for tax advantage.
Practical Dimensions of Reporting Disallowance under Section 43B(h) in Form 3CD
After understanding the background, legislative framework, and rationale behind Section 43B(h), it is important to examine how this provision plays out in actual practice. The requirement for reporting under Clause 22 of Form 3CD is not just an academic exercise; it creates tangible responsibilities for businesses, auditors, and tax authorities.
We focus on the practical dimensions of reporting disallowance under Section 43B(h) in Form 3CD. It explores the methodology for identifying relevant suppliers, the role of systems and processes in ensuring compliance, the nuances of audit reporting, and the challenges businesses are likely to face in the first few years of implementation.
Clause 22 of Form 3CD and Its Scope
Clause 22 of Form 3CD has been revised to ensure that it covers two distinct but interconnected items: the principal amounts disallowable under Section 43B(h) and the interest on delayed payments to micro and small enterprises that is inadmissible under Section 23 of the MSMED Act.
Unlike Clause 26, which deals with a range of disallowances based on actual payment before the return filing due date, Clause 22 operates on the strict timelines specified under Section 15 of the MSMED Act. This means the auditor must carefully examine whether payments were made within 15 days in the absence of a written agreement, or within the agreed period not exceeding 45 days. Any delay beyond these periods leads to permanent disallowance in the year of accrual.
The requirement is not for invoice-wise reporting but for aggregate disclosure. The auditor must report the total amount disallowable without breaking it down into individual transactions, although internal working papers should clearly capture the details to support the opinion expressed in the tax audit report.
Identification of MSE Suppliers
One of the most significant practical challenges is the identification of micro and small enterprises among the supplier base. Medium enterprises do not fall within the scope of Section 43B(h), and therefore correct classification is crucial.
Businesses are expected to obtain and maintain copies of Udyam Registration Certificates from their vendors. The Udyam portal provides self-declared registration for enterprises based on investment and turnover criteria. Suppliers registered as micro or small entities under this system qualify for the benefits and protection of the MSMED Act.
Auditors must verify whether the assessee has robust systems in place for vendor classification. This includes periodic review of vendor masters, ensuring that suppliers who upgrade to medium category continue to be treated as MSEs for three more years as per MSMED rules, and validating that purchases from unregistered vendors are excluded from disallowance under Section 43B(h).
The quality of classification directly affects the accuracy of reporting. Without reliable data, businesses risk either over-reporting disallowance or underreporting, both of which have financial and compliance implications.
Payment Timeline and Its Significance
The heart of Section 43B(h) lies in the payment timelines specified under Section 15 of the MSMED Act. These timelines differ from the traditional approach under other clauses of Section 43B, which allowed a grace period until the return filing date.
If the buyer and the MSE supplier have a written agreement, the payment must be made within the agreed time, but the maximum period allowed is 45 days from acceptance or deemed acceptance. If there is no written agreement, the period is restricted to 15 days.
The determination of the acceptance date requires attention. Acceptance occurs when the buyer acknowledges delivery of goods or services without objection. Deemed acceptance occurs if the buyer fails to raise any objection within 15 days of delivery. Therefore, businesses must have systems to record delivery dates, inspection timelines, and acceptance notes to determine the correct start of the clock for Section 15 compliance.
Any payment made beyond this statutory window becomes disallowable in the year of accrual. Unlike other Section 43B disallowances, subsequent payment before the return filing date does not restore deductibility. This represents a permanent shift in how businesses must plan their cash flows and settlement cycles.
Interest on Delayed Payments
In addition to disallowance of the principal amount under Section 43B(h), interest on delayed payments to MSEs is governed by Sections 16 and 23 of the MSMED Act. Section 16 imposes compound interest at three times the Reserve Bank of India’s bank rate for every month of delay. Section 23 clarifies that this interest is not allowable as a deduction for computing taxable income.
Clause 22 of Form 3CD requires auditors to report this inadmissible interest separately from the principal disallowance. The computation of interest requires accurate tracking of delay periods, applicable bank rates, and whether the supplier has actually claimed interest. Importantly, the liability to pay interest arises automatically under the Act, regardless of whether the supplier demands it.
This makes it essential for businesses to assess and record their potential interest liabilities even in cases where the supplier does not press the claim. Auditors must evaluate whether such liabilities have been recognized and whether the inadmissibility under Section 23 has been correctly applied.
Role of Management and Engagement Letters
While auditors are responsible for reporting under Clause 22, the primary responsibility for identifying MSE suppliers and ensuring compliance with Section 43B(h) rests with management. To avoid ambiguity, audit engagement letters should explicitly mention that management is responsible for maintaining accurate records of vendor classification, payment timelines, and interest computation under the MSMED Act.
The auditor’s role is to verify and express an opinion, not to conduct exhaustive vendor identification on behalf of management. By clarifying responsibilities at the outset, auditors can ensure that the reporting process is efficient, accurate, and free from misunderstandings.
Systems and Processes for Compliance
Given the complexity of Section 43B(h), businesses need to invest in systems and processes that integrate financial accounting with vendor compliance. Some best practices include:
- Maintaining an updated vendor master with Udyam registration details and periodic revalidation
- Recording invoice receipt dates, inspection reports, and acceptance dates in ERP systems to establish accurate payment timelines
- Generating alerts for due dates to ensure timely payments within the 15- or 45-day limits
- Segregating MSE payments from other creditors for easier compliance monitoring
- Recording contingent liabilities for interest under Section 16 even if not claimed by the supplier
These processes reduce the risk of inadvertent non-compliance and facilitate smoother audits. They also demonstrate good governance, which can strengthen business relationships with suppliers and improve credibility with regulators.
Special Situations and Interpretational Issues
Outstanding Dues as on 31 March
One common scenario is where amounts payable to MSEs remain outstanding at the end of the financial year. If these dues have crossed the permissible period under Section 15, they are disallowable for that year even if settled before the return filing date. This represents a departure from other Section 43B clauses and must be carefully captured in year-end tax computations.
Payments Cleared Before 31 March
If payments are made before the end of the financial year, no disallowance arises under Section 43B(h), even if there was a delay beyond the statutory period. However, the corresponding interest liability must still be reported under Clause 22.
Cash-Basis Taxpayers
For taxpayers following the cash system of accounting, Section 43B(h) does not result in disallowance of principal amounts because expenses are recorded only on payment. However, interest liability under Section 16, being statutorily mandated and inadmissible under Section 23, continues to apply.
Reclassified Suppliers
Suppliers that transition from micro or small to medium category retain their classification as MSEs for three years under MSMED rules. Businesses must track such transitions and apply Section 43B(h) accordingly. This requires close communication with suppliers and regular review of their Udyam status.
Compliance Verification by Auditors
Auditors must adopt a structured approach for verifying compliance under Section 43B(h):
- Obtain a list of vendors classified as MSEs along with Udyam registration certificates
- Review ageing analysis of trade payables to identify overdue payments beyond the statutory period
- Verify the calculation of interest liabilities under Section 16 and confirm inadmissibility under Section 23
- Cross-check compliance with company filings such as MSME-I for corporate entities
- Examine cheque issuance dates, bank reconciliations, and delivery records to establish payment timelines
This verification must be documented in working papers to support the auditor’s reporting under Clause 22.
Wider Business Implications
The introduction of Section 43B(h) is not merely a compliance requirement but a shift in business culture. Timely payments to MSEs are now a matter of tax discipline, financial prudence, and corporate responsibility. Businesses that fail to adapt face higher tax costs, reputational risks, and strained supplier relationships.
From a governance perspective, boards and senior management must be sensitized to the importance of these provisions. Finance teams must work closely with procurement and operations to ensure that supplier classifications are accurate and payment cycles are aligned with statutory requirements.
The provision also has implications for cash flow management. Businesses accustomed to longer credit periods must adjust their financing arrangements to ensure liquidity for timely payments. Banks and financial institutions may see increased demand for short-term working capital facilities as companies seek to align with MSMED timelines without disrupting operations.
Complexity of Vendor Identification
One of the foundational challenges under Section 43B(h) is the identification of micro and small enterprises from among the large universe of suppliers. While Udyam registration provides a statutory framework, businesses often face difficulties in:
- Obtaining timely Udyam certificates from suppliers who may be reluctant to disclose their classification
- Dealing with suppliers who are in the process of registration or whose registration status has lapsed
- Verifying authenticity of certificates and ensuring that turnover and investment criteria are in line with prescribed limits
In large organizations with thousands of vendors, updating the vendor master and ensuring accuracy of classification requires significant effort. Inaccurate classification can lead to underreporting of disallowance or excessive reporting that unnecessarily inflates taxable income.
Ambiguities Around Acceptance and Deemed Acceptance
The MSMED Act specifies that payment timelines begin from the date of acceptance or deemed acceptance of goods or services. While acceptance is relatively straightforward when delivery is acknowledged, deemed acceptance is more subjective.
For instance, if the buyer does not raise an objection within 15 days of delivery, the law treats the goods or services as accepted. However, in practical situations, businesses often conduct quality inspections that take longer, or raise objections that are informal and not recorded in writing. The absence of clear documentation creates ambiguity in determining the starting point of the payment window.
Auditors are required to rely on available records, but where records are insufficient, disputes may arise between taxpayers and tax authorities regarding the exact due date for payment under Section 15 of the MSMED Act.
Interaction with Accounting Standards
Another interpretational issue is the interaction of Section 43B(h) with accounting standards and financial reporting requirements. While tax law focuses on the deductibility of expenses, accounting standards such as Ind AS or AS-29 deal with recognition of liabilities and provisions.
The requirement to disallow principal payments not made within MSMED timelines creates situations where expenses are booked in financial accounts but disallowed in tax computations. This leads to temporary timing differences and may affect deferred tax accounting. Businesses must reconcile these differences carefully to avoid inconsistencies between financial statements and tax audit reports.
Treatment of Advances and Partial Payments
Situations often arise where businesses make partial payments to MSE suppliers or provide advances before delivery. The treatment of such payments under Section 43B(h) is not explicitly detailed in the legislation.
- If part of the invoice is paid within the statutory timeline and the balance is delayed, the question arises whether only the delayed portion should be disallowed or whether the entire invoice amount becomes ineligible.
- Similarly, if an advance is paid but the balance is cleared beyond the due date, should the advance portion escape disallowance?
These nuances require careful interpretation, and in the absence of judicial precedents, businesses must rely on reasonable and consistent practices, supported by documentation, to withstand scrutiny.
Impact on Supply Chain and Vendor Relationships
The strict disallowance provisions under Section 43B(h) have broader business consequences. Suppliers, especially micro and small enterprises, may use the provision as leverage to demand faster payments, knowing that delayed settlement creates tax disallowances for buyers.
This can disrupt traditional supply chain financing models where larger buyers enjoyed longer credit periods. Companies may need to renegotiate terms with suppliers, arrange for additional working capital facilities, or prioritize payments to MSEs over other creditors to optimize tax outcomes.
At the same time, the provision could improve vendor relationships by ensuring that smaller businesses receive their dues promptly. From a policy perspective, this aligns with the government’s objective of strengthening the financial health of micro and small enterprises.
Role of Auditors and Risk of Litigation
Auditors face unique challenges in reporting under Clause 22 of Form 3CD. Unlike other disallowances, where documentary evidence of payment before the return filing date suffices, reporting under Section 43B(h) requires auditors to form an opinion on whether payments were made within MSMED timelines.
This introduces subjectivity into the audit process. Disagreements may arise between auditors and management regarding the classification of vendors, determination of acceptance dates, or computation of interest liabilities. In such cases, auditors must exercise professional judgment and document their rationale clearly to defend their reporting position.
The risk of litigation is also significant. Tax authorities may challenge the classification of suppliers, the interpretation of timelines, or the computation of disallowances. Given the novelty of the provision, litigation is likely to increase in the initial years until judicial clarity emerges.
Enforcement and Role of Tax Authorities
From the perspective of tax authorities, Section 43B(h) introduces a new area of scrutiny. Assessing officers may seek detailed vendor lists, Udyam certificates, and ageing analyses of trade payables to verify compliance.
There is also the possibility of cross-verification with filings under company law, such as MSME-I, which requires companies to disclose dues to micro and small enterprises. Discrepancies between these disclosures and tax audit reports could attract questions and penalties.
The success of enforcement will depend on the capacity of tax authorities to understand the interplay between the Income-tax Act and the MSMED Act, and to apply these provisions consistently across cases.
Special Concerns for Certain Industries
Industries with complex supply chains or reliance on multiple small vendors face particular difficulties under Section 43B(h).
- Manufacturing companies sourcing raw materials from numerous small suppliers must build systems to track invoices and payments with precision.
- Service industries engaging freelancers or small contractors must verify whether such parties fall within the scope of micro or small enterprises.
- Construction and infrastructure projects, where payment cycles are traditionally long, may be most affected as the provision disrupts established practices.
The challenges vary by industry, but the common requirement is the need for robust systems, proactive vendor management, and close coordination between procurement and finance teams.
Judicial Developments and Expected Clarifications
As Section 43B(h) begins to apply from assessment year 2024–25, judicial precedents are yet to emerge. However, certain themes are expected to surface in litigation:
- Whether disallowance applies even if the supplier does not raise a claim under the MSMED Act
- How partial payments and advances are to be treated in computing disallowance
- Whether disputes over quality or delivery can extend the acceptance period and delay the start of payment timelines
- The extent of auditor’s responsibility in verifying vendor classification versus management’s primary role
Over time, clarifications from the Central Board of Direct Taxes and rulings from tribunals and courts will shape the practical interpretation of Section 43B(h). Until then, businesses must adopt conservative approaches and maintain detailed documentation to defend their tax positions.
Future Outlook and Policy Implications
Looking ahead, Section 43B(h) represents a significant policy shift in aligning tax incentives with economic priorities. By linking tax deductibility to timely payments, the government has created a strong incentive for businesses to support the financial health of micro and small enterprises.
In the future, several developments may be expected:
- Integration of Udyam registration data with tax filing systems to enable automated identification of MSE suppliers
- Mandatory disclosure of MSE dues in financial statements and tax returns to improve transparency
- Possible extension of similar provisions to other areas of economic policy where timely compliance is critical
- Increased emphasis on digital payments and real-time reconciliation to monitor adherence to MSMED timelines
Businesses that adapt early to these changes will be better positioned to manage risks, optimize cash flows, and build stronger supply chain relationships.
Capacity Building and Awareness
For effective implementation of Section 43B(h), capacity building is essential across multiple stakeholders. Businesses must train procurement and finance teams to understand the importance of vendor classification and timely payment. Auditors must update their methodologies to capture the unique requirements of Clause 22 reporting. Tax authorities must develop expertise in applying the provision consistently and fairly.
Professional bodies, industry associations, and chambers of commerce have a role in disseminating knowledge, sharing best practices, and engaging with policymakers to resolve practical difficulties. Without widespread awareness and preparation, the risk of non-compliance and litigation will remain high.
Conclusion
The introduction of Section 43B(h) by the Finance Act, 2023 marks a transformative moment in the Indian tax and business landscape. By directly linking the deductibility of business expenditure to timely payments under the MSMED Act, the law seeks to ensure that micro and small enterprises, which form the backbone of the economy, are not deprived of their rightful dues. Unlike earlier provisions where tax compliance often operated in isolation, this amendment integrates financial discipline with social and economic responsibility.
From the legislative framework discussed to the practical reporting requirements in Form 3CD examined, and the challenges, interpretations, and forward-looking insights highlighted, the picture that emerges is one of both opportunity and responsibility. Businesses now face the dual task of strengthening internal systems to track supplier classifications and payment timelines while simultaneously aligning their tax strategies with broader policy objectives.
Auditors, too, carry an enhanced responsibility under Clause 22 of Form 3CD. Their role goes beyond mechanical verification, requiring professional judgment in evaluating whether payments fall within statutory timelines, whether suppliers qualify as micro or small enterprises, and how delayed settlements impact both principal disallowances and inadmissible interest. This shift demands not just technical expertise but also close collaboration with management and stakeholders to ensure compliance.
The provision will inevitably pose short-term challenges. Vendor identification, deemed acceptance, reconciliation with financial reporting, and litigation risks are real concerns. Industries with long payment cycles or decentralized vendor networks may experience disruptions. Yet, in the long run, the positive impact is undeniable. Section 43B(h) has the potential to instill greater financial discipline, improve liquidity for micro and small enterprises, and strengthen the overall ecosystem of trust in commercial transactions.
The future of Section 43B(h) will be shaped by judicial precedents, administrative clarifications, and technological innovations. Integration of Udyam registration databases with tax platforms, enhanced disclosures, and digitization of supply chain payments could further streamline compliance. As these developments unfold, businesses that embrace transparency, adopt robust systems, and engage proactively with auditors and regulators will find themselves at an advantage.
Ultimately, the provision is not merely a tax disallowance clause but a policy tool designed to encourage timely settlement of dues. By fostering accountability and ensuring that smaller enterprises receive payments without undue delay, Section 43B(h) supports the larger goal of inclusive growth. It is a reminder that tax law, when aligned with economic priorities, can be a powerful driver of fairness, efficiency, and sustainability in business practices.