Section 41(1) addition not justified for loan creditors

Shri K A Rame Gowda Vs ACIT (ITAT Bangalore)

Admittedly in this case, the addition has been made by invoking the provisions of section 41(1) of the I.T.Act. A plain reading of section 41(1) of the I.T.Act make it clear that the said section will have application only if the following conditions are satisfied:-

(i) an allowance or deduction had been made, in the computation of profits and gains of a business or profession, in the assessment for any year in respect of los

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