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    <title>2020 (9) TMI 86 - ITAT DELHI</title>
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    <description>Notional interest on a security deposit cannot be taxed as income from other sources merely because interest might hypothetically have been earned. The addition failed because it was based only on assumption, with no material showing actual receipt, accrual, or any applicable deeming provision under the Income-tax Act, 1961. Income tax cannot be levied on a mere possibility of earning or an imagined benefit. On that basis, the notional interest was held not taxable and the proposed addition was unsustainable.</description>
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      <description>Notional interest on a security deposit cannot be taxed as income from other sources merely because interest might hypothetically have been earned. The addition failed because it was based only on assumption, with no material showing actual receipt, accrual, or any applicable deeming provision under the Income-tax Act, 1961. Income tax cannot be levied on a mere possibility of earning or an imagined benefit. On that basis, the notional interest was held not taxable and the proposed addition was unsustainable.</description>
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