Notional locker rent addition rejected as banking income treatment prevailed for the co-operative bank.

Notional attribution of locker rent from depositors was held unsustainable as taxable income in the assessee bank's hands. The Tribunal treated locker rent derived by a co-operative bank as income from banking business and found no factual basis for a notional addition. The addition was therefore deleted, with the issue decided in favour of the assessee.

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Issues: Whether locker rent attributed on a notional basis from depositors could be sustained as taxable income in the assessee bank's hands.

Analysis: The assessment arose under section 143(3) of the Income-tax Act, 1961. The Tribunal noted that locker rent derived by a co-operative bank had been treated as income from banking business and that the notional addition was not justified on the facts.

Conclusion: The addition on account of locker rent on a notional basis was not sustainable and the issue was decided in favour of the assessee.

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