TMI Blog2013 (8) TMI 1019X X X X Extracts X X X X X X X X Extracts X X X X ..... . As regards the contention of the assessee that the said interest has not been paid to the assessee due to the litigation with the debtors, in our view is not acceptable as the AO and the Ld.CIT(A) has correctly held that there is no dispute between the assessee and the parties to whom the loans have been made on this issue. Mere fact that the said parties have not paid the impugned interest to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elate to the addition of interest amounting to ₹ 6,68,233/-, 7,48,222/-, 8,38,234/- 9,38,821/- respectively for the assessment years 2003-04, 2004-05, 2005-06 2006-07 on notional basis. 3. Briefly stated, the assessee, a firm in the returns of income for the assessment years 2001-02 2002-03, has offered interest income on accrual basis on the loans given to family members namely Kir ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e impugned orders, the assessee has filed these appeals before us. 4. Before us, the Ld. AR has reiterated the same submissions made before the lower authorities which inter alia include that the assessee has not actually received any interest till today and there is no likelihood of any receipts at any time in future also. The assessee has not offered the interest to tax since the loan parties ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat the assessee has been continuously following the mercantile system of accounting and the assessee has not proved that in the years 2001-02 and 2002-03, the assessee has offered the interest for tax on the basis of actual receipt. It is pertinent to note that the assessee has not provided any material/evidence to establish that there has been a claim for the repayment of the loan/interest and a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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