Trade Advances Retained for 15 Years: Tax Additions Confirmed u/s 41(1) for Unreturned Customer Payments.

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....Cessation of liability u/s 41(1) - Incomplete project - Assessee has received trade advance for sale of certain flats to prospective buyers which were ultimately not construed by it and incomplete project was sold under the head “work-in-progress”. It has not returned money to these customers in the last fifteen years. It has not created an arrangement with buyer of the WIP that these customers would get flats at reduced price by the amount received by the assessee as advance. It has simply retained these amounts under the garb of liability without paying any taxes. - Additions confirmed - AT....