Where the impugned liabilities do not represent any trading liability since the assessee had never commenced business and had therefore never incurred any operational expense or earned any income. Further there is nothing on record to show that the liabilities ceased to exists. Therefore, the liabilities did not represent any expense rather an advance. (AY. 2014-15)
Brahma Steyr Tractors Ltd. v. ITO (2020) 203 TTJ 33 (Chd.)(Trib.)
S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Not commenced business-Not trading liability-Nothing to show the liabilities ceased to exist.