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    <title>2021 (8) TMI 119 - ITAT DELHI</title>
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    <description>Same income cannot be taxed twice by artificially splitting a disclosed peak balance across assessment years; the addition was unsustainable because the amount had already been offered to tax and paid in the relevant year. Notional interest also cannot be added on a foreign bank balance without material showing that interest was actually earned; an estimate based only on a domestic savings-rate assumption had no evidentiary foundation. On both issues, the additions were deleted and relief was granted to the assessee.</description>
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      <description>Same income cannot be taxed twice by artificially splitting a disclosed peak balance across assessment years; the addition was unsustainable because the amount had already been offered to tax and paid in the relevant year. Notional interest also cannot be added on a foreign bank balance without material showing that interest was actually earned; an estimate based only on a domestic savings-rate assumption had no evidentiary foundation. On both issues, the additions were deleted and relief was granted to the assessee.</description>
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