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2021 (9) TMI 222 - AT - Income TaxAddition u/s 56 - addition on account of locker rent on presumption basis - interest earned on deposit received against the locker facility - AO noticed that assessee has not collected any rent towards safe deposit vaults allotted to its customer and deposits was collected from customers against allotment of safe deposit vaults - HELD THAT:- On the perusal of the copy of balance sheet placed in the Paper Book it is noticed that assessee has shown the amount of safe vault deposit in the liabilities side under the head deposits claiming that same was invested in working capital of bank for providing loans and making investments - interest income from loan and investment was reflected in the Profit and Loss Account and Income Tax Return was filed as per profit shown in the Profit and Loss Account. - In the decision of the Coordinate Bench of the ITAT in the case of Co-op. Bank of Mehsana Ltd. [2019 (1) TMI 1917 - ITAT AHMEDABAD] wherein the similar issue on identical facts has been adjudicated in favour of the assessee - We find merit in the submission of the assessee and allow the appeal of the assessee as charging of notional interest is not justified. - Decided against revenue.
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