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2021 (6) TMI 306

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..... , such hypothetical income cannot be charged to tax. In the case of mercantile system of accounting, an accruing income can be charged to tax only when it is likely to be received under the given circumstances. Even the principal amount of deposit made by the assessee became irrecoverable. These facts indicate that the assessee did not receive any such interest income from Rupee Co-op Bank Ltd. .....

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..... Shri S.S.Viswanethra Ravi, Judicial Member For the Assessee : None For the Revenue : Shri Vitthal Bhosale ORDER PER R.S. SYAL, VP : This appeal by the assessee arises out of the order dated 04-12-2017 passed by the CIT(A)-3, Pune in relation to the assessment year 2013-14. 2. The only issue raised in the appeal is against the confirmation of addition of ₹ 26,125 .....

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..... hat was not disclosed. The bank had become defunct and no financial transactions were allowed. The RBI, vide its direction dated 21-02-2013, referred to on page 16 of the impugned order, banned the transactions of the bank. Due to such a ban, even the principal amount deposited by the assessee became doubtful of recovery, much less the interest in question that was not received. Not only that, the .....

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..... income, after its accrual, is marred with complete uncertainty as to its realization, such an accrual gets deferred to the point of clearing of the clouds of uncertainty over it. 7. Assimilating the entire factual scenario prevailing in the instant case, it is seen that even the principal amount of deposit made by the assessee became irrecoverable. These facts indicate that the assessee did no .....

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