https://www.taxtmi.com/caselaws?id=446035 Interest on inter-corporate deposits could not be taxed on a merely notional basis without first verifying whether income had actually accrued. The Tribunal held that the key enquiry was whether the amount had become irrecoverable before accrual or only after accrual, and applied the real income theory to reject addition absent foundational factual verification. The Supreme Court authority relied on by the revenue was found inapposite on these facts. The matter was restored to the Assessing Officer for fresh examination of accrual and irrecoverability, and the assessee's grounds were allowed for statistical purposes. en-us Fri, 25 Aug 2023 00:00:00 +0530 Fri, 24 Nov 2023 07:42:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446035 Interest on inter-corporate deposits could not be taxed on a merely notional basis without first verifying whether income had actually accrued. The Tribunal held that the key enquiry was whether the amount had become irrecoverable before accrual or only after accrual, and applied the real income theory to reject addition absent foundational factual verification. The Supreme Court authority relied on by the revenue was found inapposite on these facts. The matter was restored to the Assessing Officer for fresh examination of accrual and irrecoverability, and the assessee's grounds were allowed for statistical purposes. Case-Laws Income Tax Fri, 25 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446035