Parameters on cessation of liability to be taxed u/s 41(1) of Income Tax Act

PCIT Vs Soorajmul Nagarmull (Calcutta High Court) What are the parameters to consider the cessation of liability to be taxed u/s 41(1) of the Income-tax Act,1961 and relation with the limitation Act 1963? The Division bench of Calcutta High Court in this case even though was not satisfied about the grounds for condonation of 627 days delay in filing the appeal , was not inclined to dismiss Section 260A appeal on technical ground in view of important question of law involved in this appeal where the ITAT had allowed assessees’ appeal regarding addition of Rs 12.63 crore u/s 41(1) in respect o...