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ITAT allowed the appeal of the assessee, deleting additions made on account of notional commission and interest on unpaid commission arising from a business arrangement with CPRPL. ITAT held that no real income had accrued to the assessee, as CPRPL had neither recorded any liability nor paid commission, lease rent, or interest, and the assessee had not received any such amounts during the relevant assessment year. A mere unilateral claim raised by the assessee through a letter, which CPRPL did not act upon, could not give rise to taxable income. ITAT noted that capital gains were correctly offered and taxed in AY 2020-21 upon actual registration of the property.
ITAT allowed the appeal of the assessee, deleting additions made on account of notional commission and interest on unpaid commission arising from a business arrangement with CPRPL. ITAT held that no real income had accrued to the assessee, as CPRPL had neither recorded any liability nor paid commission, lease rent, or interest, and the assessee had not received any such amounts during the relevant assessment year. A mere unilateral claim raised by the assessee through a letter, which CPRPL did not act upon, could not give rise to taxable income. ITAT noted that capital gains were correctly offered and taxed in AY 2020-21 upon actual registration of the property.
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