Dismissing the appeal of the revenue the Court held that , Loan waiver cannot be assessed as cessation of liability if the assessee has not claimed any deduction . High Court observed that the Honourable Supreme Court in CIT v Mahindra & Mahindra Ltd ( 2018) 404 ITR 1 ( SC)  held that , on a plain reading of S.28(iv) of the Act , it appears that for the applicability of said provision , the income which can be taxed shall arise from the business or profession . Also on order to invoke this provision , the benefit which is received has to be in some other from rather than in the safe of money. If that is because of the remission loan liability , then , this section would not be attracted . ( ITA No. 431 of 2016 dt. 21-08-2018) ( AY.2008-09) (Arising from , ITA No .6211 / Mum/ 2011 dt. 17-06-2015).