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2019 (1) TMI 2001 - ITAT DELHIBenefit/perquisite u/s. 2(24)(iv) - additions as on account of notional interest - As argued assessee has neither received any interest income nor any interest income has accrued to it. It is only a real income that can be brought to tax. In the absence of any real income, there could be no taxability. The addition made by the A.O. are of hypothetical income and not of any real income - HELD THAT:- The matter requires reconsideration at the level of the A.O. The Ld. CIT(A) in this case following his Order for the A.Y. 2010-2011 allowed the appeal of assessee. The Ld. D.R. however filed copy of the Order of the Tribunal [2018 (3) TMI 1575 - ITAT DELHI] Dated 26.03.2018 in the case of same assessee in which for A.Y. 2009-2010 [2018 (3) TMI 1575 - ITAT DELHI], the Tribunal has considered the similar issue in Departmental Appeal on Ground No.3 - “On the facts and circumstances of the case, the Ld. CIT(A) has erred in deleting the addition made by the A.O. on account of benefit of perquisite under section 2(24)(iv) of the I.T. Act, 1961 Following the reasons for decision of the Coordinate Bench of the Tribunal, we set aside the Orders of the authorities below and restore the matter in issue to the file of A.O. for reconsideration as is directed by the Tribunal vide Order dated 26.03.2018 [2018 (3) TMI 1575 - ITAT DELHI] Appeal of the Department is Allowed for statistical purposes.
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