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Case lawCBDT Circulars & Instructions › Statutory position — s.176: accelerated assessment on discontinuance, the fifteen-day notice in s.176(3), and the deeming of post-discontinuance receipts in s.176(3A) for a business and s.176(4) for a profession
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Statutory position — s.176: accelerated assessment on discontinuance, the fifteen-day notice in s.176(3), and the deeming of post-discontinuance receipts in s.176(3A) for a business and s.176(4) for a profession

I shut my consultancy two years ago and money is still coming in for work I did before I closed. My accountant says section 176 taxes it. Which sub-section does that, what notice was I supposed to give when I closed, and how much time did I have?

I shut my consultancy two years ago and money is still coming in for work I did before I closed. My accountant says section 176 taxes it. Which sub-section does that, what notice was I supposed to give when I closed, and how much time did I have?

Two different sub-sections do the deeming and it matters which one you are in. Section 176(3A) covers a discontinued BUSINESS: any sum received after the discontinuance is deemed to be the income of the recipient and charged to tax in the year of receipt, if it would have been included in the total income of the person who carried on the business had it been received before the discontinuance. Section 176(4) covers a discontinued PROFESSION, but only where the discontinuance was on account of the cessation of the profession by, or the retirement or death of, the person carrying it on, and it deems the sum received after discontinuance to be the income of the recipient charged to tax in the year of receipt on the same 'would have been included' condition. Separately, s.176(3) requires any person discontinuing any business or profession to give the Assessing Officer notice of the discontinuance within fifteen days of it.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1989-04-01, reported as Income-tax Act, 1961, s.176, sub-sections (1) to (7), as printed on the Year 2024 (No. 2) departmental page. It bears on section 176, section 176(1), section 176(2), section 176(3), section 176(3A), section 176(4), section 176(5), section 176(6), section 176(7), section 142(1), section 148, section 4 of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Still good law. Five departmental pages spanning Year 2000 to Year 2024 (No. 2) print sub-sections (1) to (7) in the same words, which is the strongest evidence available on this pass that the section has not been altered since the 1989 amendments footnoted on the older pages. That is not the same as reading a Finance Act, and no Finance Act text was retrieved. The Year 2025 page (/w/section-176-64) prints sub-sections (2), (3), (3A) and (4) in the same words, so the run of identical text now extends unbroken from Year 2000 to Year 2025; no page stamped Year 2026 was located. Whether the deeming in sub-section (4) can be given effect where the recipient carried on no profession in the year of receipt is judicially contested; see the two entries in this library on Commissioner of Income-tax v. Justice R.M. Datta and V. Parthasarathy v. Addl. Commissioner of Income-tax.

Why it matters

This entry corrects a mis-description that circulates widely, including in the brief that commissioned it. Section 176(2) is not about a profession discontinued on death; it is the rating rule, providing that the total income of each completed previous year or part of a previous year in the accelerated period is chargeable at the rate or rates in force in that assessment year and that separate assessments are to be made for each. And section 176(3A) is not a notice provision; the notice provision is s.176(3) alone, and (3A) is the deeming of a post-discontinuance business receipt. Getting that right decides which condition you must satisfy: (3A) applies to any discontinuance of a business, however it came about, whereas (4) applies to a profession only if the discontinuance was on account of cessation by, or retirement or death of, the person carrying it on. Beyond that, three limits are worth knowing. Section 176(1) is discretionary and prospective in a special way: 'notwithstanding anything contained in section 4', where a business or profession is discontinued in any assessment year, the income from the expiry of the previous year for that assessment year up to the date of discontinuance MAY, at the discretion of the Assessing Officer, be charged to tax in that assessment year — the Assessing Officer may accelerate, and if he does not, the ordinary previous-year machinery applies. Section 176(6) makes the tax chargeable under the section additional to any tax chargeable under any other provision. And section 176(7) allows a notice under section 142(1)(i) or section 148 in a case where sub-section (1) applies to require a return in a period 'not being less than seven days' — which is the shortest compliance window in the Act and worth knowing before you assume the usual thirty. Whether a receipt caught by the deeming in s.176(4) can in fact be brought to charge, given that the head of income and the computation provisions have to be satisfied as well, is a separate and contested question; this library carries both sides of it.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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Related

Other authorities on the same sections.