No Liability Written Back, Section 41(1) Can’t Apply

Akshay Gujral Vs DCIT (ITAT Delhi) No Entry Written Back, No 41(1): ITAT Delhi Deletes ₹10 Lakh ‘Cessation of Liability’ Addition Delhi ITAT “SMC” Bench  allowed the appeal of Akshay Gujral for AY 2016-17 and deleted the addition of ₹10 lakh made u/s 41(1) on account of alleged cessation of liability. The AO, in proceedings u/s 153C/143(3), treated the amount as income on the premise of cessation of liability, which was affirmed by the CIT(A). However, the Tribunal noted a fatal jurisdictional lapse—the assessment order did not record any finding that the liability had actually ...