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Case lawHigh Court › V. Parthasarathy v. Addl. Commissioner of Income-tax (Andhra Pradesh High Court, 11 September 1975) — 'discontinuance' in section 176(4) covers temporary and involuntary cessation, so an advocate elevated to the Bench has discontinued his profession
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V. Parthasarathy v. Addl. Commissioner of Income-tax (Andhra Pradesh High Court, 11 September 1975) — 'discontinuance' in section 176(4) covers temporary and involuntary cessation, so an advocate elevated to the Bench has discontinued his profession

I stopped practising only because I was appointed a judge, and I went back to the Bar when I retired. Surely that is a suspension and not a discontinuance, so section 176(4) cannot apply to fees I received while I was on the Bench?

I stopped practising only because I was appointed a judge, and I went back to the Bar when I retired. Surely that is a suspension and not a discontinuance, so section 176(4) cannot apply to fees I received while I was on the Bench?

That argument was run and rejected. The Andhra Pradesh High Court held that both 'discontinuance' and 'cessation' in section 176(4) take in temporary as well as permanent discontinuance, that the length of time for which the profession is stopped is not an element of the concept, and that the question whether the cessation was voluntary or involuntary has no bearing on the application of the sub-section. It also rejected the reading that the sub-section is confined to discontinuance by retirement or death, holding that the words 'on account of' govern cessation of the profession, retirement and death equally. The writ petition was dismissed.

Decided by the High Court (Single Judge, High Court of Andhra Pradesh (the judgment is written in the first person singular; the judge's name is not printed on the text available at either URL read this pass)) on 1975-09-11, reported as Writ petition under Article 226 of the Constitution; assessment years 1969-70 and 1970-71. The decision is cited in Commissioner of Income-tax v. Justice R.M. Datta as V. Parthasarathy v. Addl. CIT [1976] 103 ITR 508.. It bears on section 176(4), section 176, section 176(1), section 176(2), section 176(3), section 264, section 4, section 14, section 56 of the Income Tax Act 1961, in Assessment & Scrutiny and How Tax Law Is Read matters.

Validity check could not be completed. Validity check could not be completed. I did NOT run a later-treatment search on this decision beyond reading how it was dealt with in Commissioner of Income-tax v. Justice R.M. Datta (Calcutta High Court, 4 July 1989), which is a separate entry in this library. That Court held at its paragraph 22 that this decision 'is only an authority for the proposition that even involuntary suspension of the profession of law consequent upon the assessee's elevation to the office of judge amounts to discontinuance of the profession within the meaning of Section 176(4) of the Act', and that the contentions urged before it 'were neither raised before the Andhra Pradesh High Court nor were adjudicated upon by the Andhra Pradesh High Court'. On that reading the two decisions are not in head-on conflict, which is why the label here is 'unverified' and not 'high courts differ'; but the practical consequence is that a receipt of this kind may be held to arise from a discontinuance on this decision and yet be held not chargeable on the Calcutta reasoning, and a practitioner must argue both stages. No Supreme Court decision on the head-of-charge question under section 176(4) was located this pass. The text of section 176 reproduced in this judgment is the pre-1976 text and is not the current law.

Why it matters

This is the Revenue's side of the section 176(4) line and the answer to the most attractive argument a retired judge or a professional on a career break has. The Court's grammatical point is the one to be ready for: the clause is to be read as though it said 'where any profession is discontinued in any year on account of the cessation of the profession by the person carrying on the profession, or where any profession is discontinued in any year on account of the retirement of the person, or where any profession is discontinued in any year on account of the death of the person' — so cessation is an independent trigger and not merely a preface to retirement and death. Its second point is that discontinuance means stoppage, and that if permanence were required only death would qualify in a profession, which the Court thought an unreasonable reading. It supported that from the converse side, with the Calcutta decision in CIT v. Sarat Chandra Bose [1950] 18 ITR 669 under section 25(3) of the 1922 Act, where an assessee argued for temporary discontinuance to get relief, and with Justice Iqbal Ahmad, In re, where cessation on appointment to the Bench was held to be discontinuance for section 25(3). And it recorded the provision's origin: it was introduced on the recommendation of the Direct Taxes Administration Enquiry Committee of 1958-59, which said there was no provision to assess income received after the cessation of practice, retirement or death of solicitors, advocates, doctors, consulting surveyors and engineers. Read the limits carefully, because they are what a taxpayer should exploit. The Court did NOT decide whether such a receipt can be computed and brought to charge at all: it noted at its paragraph 16 that the Revenue's alternative case that the income was chargeable as income from other sources did not arise, because neither the Income-tax Officer nor the Commissioner had assessed it on that footing and the tax had been assessed having regard to section 176(4). The head-of-charge and further-fiction contentions that succeeded in Calcutta in Commissioner of Income-tax v. Justice R.M. Datta were never argued here — that Court said so expressly.

Binding within that High Court's jurisdiction. Persuasive elsewhere.

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.