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Income Tax - Highlights / Catch Notes

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Revision u/s 263 - addition on account of notional interest @10% ...


No Notional Interest Income for Assessee Post-Amalgamation; Income Must Accrue or Be Received to Be Taxed.

January 30, 2024

Case Laws     Income Tax     HC

Revision u/s 263 - addition on account of notional interest @10% on deposit - The High court upheld the concurrent findings of the ITAT and the CIT(A) that no notional interest income accrued to the assessee, after its amalgamation, as per the loan agreement clause. - This decision was based on the principle that income cannot be taxed on a purely notional basis; it must either accrue as per agreement terms or be received by the assessee.

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