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ITAT allowed the appeal, holding that the Assessing Officer's addition of notional interest on interest-free mobilization and additional advances was unsustainable. Clause 6 obliged the assessee to provide a 15% interest-free mobilization advance recoverable pro rata from the Principal EPC Contractor's bills, and further advances were similarly recoverable. CIT(A) found on ledger evidence that about 95% of the mobilization and additional advances were recovered by 30.09.2017 and the balance settled by 01.12.2019. The tribunal accepted that interest incurred on bank borrowings was capitalised into project cost and amortised over the concession period, concluding no taxable notional income arose and the impugned addition must be deleted.
ITAT allowed the appeal, holding that the Assessing Officer's addition of notional interest on interest-free mobilization and additional advances was unsustainable. Clause 6 obliged the assessee to provide a 15% interest-free mobilization advance recoverable pro rata from the Principal EPC Contractor's bills, and further advances were similarly recoverable. CIT(A) found on ledger evidence that about 95% of the mobilization and additional advances were recovered by 30.09.2017 and the balance settled by 01.12.2019. The tribunal accepted that interest incurred on bank borrowings was capitalised into project cost and amortised over the concession period, concluding no taxable notional income arose and the impugned addition must be deleted.
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