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The ITAT Delhi, in a case involving penalty u/s 271(1)(c) for alleged concealment of income related to notional accruals/interest on a foreign bank account balance at HSBC Bank, Geneva, held that notional interest on the addition made in a previous assessment year could not be applied in subsequent years. Citing a Delhi High Court ruling, the Tribunal ruled in favor of the assessee, deleting the addition made by the AO and upheld by the CIT(A) for the assessment year in question, as the facts and legal principles remained consistent with the precedent.
The ITAT Delhi, in a case involving penalty u/s 271(1)(c) for alleged concealment of income related to notional accruals/interest on a foreign bank account balance at HSBC Bank, Geneva, held that notional interest on the addition made in a previous assessment year could not be applied in subsequent years. Citing a Delhi High Court ruling, the Tribunal ruled in favor of the assessee, deleting the addition made by the AO and upheld by the CIT(A) for the assessment year in question, as the facts and legal principles remained consistent with the precedent.
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