https://www.taxtmi.com/caselaws?id=447541 The ITAT Cochin upheld additions under section 41(1) for cessation of liability regarding freezer deposits. The assessee-company collected refundable deposits from distributors for deep freezer installations, with amounts reducing annually at 25% depreciation rate. The tribunal held that yearly reduction in refundable amounts constituted income as the assessee acquired unqualified rights over non-refundable portions, regardless of accounting treatment. The cessation of liability created taxable income in the year of accrual, not upon agreement termination. Regarding section 14A disallowance, the tribunal found no fund diversion and noted the assessee had sufficient own funds for tax-free investments. The appeal was partly allowed. en-us Mon, 11 Dec 2023 00:00:00 +0530 Fri, 29 Dec 2023 08:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447541 The ITAT Cochin upheld additions under section 41(1) for cessation of liability regarding freezer deposits. The assessee-company collected refundable deposits from distributors for deep freezer installations, with amounts reducing annually at 25% depreciation rate. The tribunal held that yearly reduction in refundable amounts constituted income as the assessee acquired unqualified rights over non-refundable portions, regardless of accounting treatment. The cessation of liability created taxable income in the year of accrual, not upon agreement termination. Regarding section 14A disallowance, the tribunal found no fund diversion and noted the assessee had sufficient own funds for tax-free investments. The appeal was partly allowed. Case-Laws Income Tax Mon, 11 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447541