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Case lawCBDT Circulars & Instructions › Statutory position — s.59: the s.41(1) deemed-income rule applied to income from other sources
CBDT Circulars & InstructionsCuts both wayss.59s.41(1)s.56s.57

Statutory position — s.59: the s.41(1) deemed-income rule applied to income from other sources

I was allowed a deduction under s.57 in an earlier year for a liability that has now been written back. Is the write-back taxable, and under which head?

I was allowed a deduction under s.57 in an earlier year for a liability that has now been written back. Is the write-back taxable, and under which head?

Yes, and under the head income from other sources. Section 59(1) provides that s.41(1) applies, so far as may be, in computing the income of an assessee under s.56 as it applies in computing income under the head profits and gains of business or profession. Sub-sections (2) and (3) of s.59 stand omitted.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 1962-04-01, reported as Section 59, Income-tax Act, 1961; sub-sections (2) and (3) omitted. It bears on section 59, section 41(1), section 56, section 57 of the Income Tax Act 1961, in Assessment & Scrutiny, Deductions & Disallowances and How Tax Law Is Read matters.

Still good law. The text was read on a departmental page carrying the 'Year: 2025' stamp with the correct heading and Act name, checked against the year-stamped page for 2022, and corroborated in a High Court judgment that reproduces the operative words. No decided authority construing s.59 was located, so nothing is stated here about how the courts have applied it; the s.41(1) authorities already in this library are the nearest guide and are carried across only subject to the words 'so far as may be'.

Why it matters

This is the provision most practitioners forget, and it works in both directions. For the Assessing Officer it supplies the charge on a remission or cessation of a liability, or a recovery of an amount, where the deduction was originally allowed against income from other sources — without it, s.41(1) on its own terms speaks only of the business head and could not reach the write-back. For the taxpayer it supplies the defence: the words carried across from s.41(1) require that an allowance or deduction has actually been made in an earlier year in respect of the loss, expenditure or trading liability, and that the assessee has since obtained some benefit in respect of it. If no deduction was ever allowed under s.57, s.59 has nothing to operate on. That is exactly how the Departmental Representative put it in Bharti Bhushan Jindal v. ACIT — that only where a deduction is allowed under s.57(iii) are the provisions of s.59(1) to be applied. It also means the whole body of s.41(1) case law — that a unilateral book entry writing off a liability is not by itself a cessation, and that limitation barring the creditor's remedy does not extinguish the debt — travels across, subject to the 'so far as may be' qualification.

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

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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Related

Other authorities on the same sections.