Sec. 41(1) additions justified if liability of shipping agent to pay port storage rent back to customer had ceased

IT: Where assessee, a shipping agent, received amounts from its customers towards ground rent payable to Port Trust as storage charges for containers of its customers but did not pay same to Port Trust for reason that ground rent charges were in dispute and Tariff Authority for Major Ports (TAMP) had not finally fixed rent charges and same was shown as liability in its books of account, in view of fact that TAMP had passed final order fixing rent charges and, therefore, liability of assessee to

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