No addition can be made u/s 41(1) unless Revenue establishes that such liability has seized even if assessee doesn’t furnish details, addresses and identity of the creditors:

AO made an addition u/s 41(1) since the assessee had not furnished details, addresses and identity of the creditors at the assessment stage. ITAT deleted the said addition after holding that onus is on the Revenue to establish that the liability has seized and the Revenue had failed to establish the same. On Revenue’s appeal, the Hon’ble High Court upheld the ITAT’s view and dismissed Revenue’s appeal.

[MUKESH PRINTS - TAX APPEAL NO.264 of 2012 - GHC]