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    <title>2021 (2) TMI 20 - ITAT BANGALORE</title>
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    <description>Overdue interest on an unrecovered contractual debt was not taxable on accrual basis where it had remained unpaid for years, was no longer recognised in the books, and recovery remained uncertain. The mercantile system did not by itself create taxable income; the interest had to accrue in a real and enforceable sense before it could be brought to tax. Applying the real income principle, the addition could not be sustained on notional accrual alone, and the deletion of the addition was upheld in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=403528</link>
      <description>Overdue interest on an unrecovered contractual debt was not taxable on accrual basis where it had remained unpaid for years, was no longer recognised in the books, and recovery remained uncertain. The mercantile system did not by itself create taxable income; the interest had to accrue in a real and enforceable sense before it could be brought to tax. Applying the real income principle, the addition could not be sustained on notional accrual alone, and the deletion of the addition was upheld in favour of the assessee.</description>
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