https://www.taxtmi.com/caselaws?id=768224 ITAT Mumbai dismissed revenue's appeal regarding notional interest addition on Rs. 30 crores interest-free loan received by assessee from RPTPL under pre-emption rights agreement dated 26/10/2016. AO incorrectly applied Rule 3(7)(i) for calculating notional interest, which applies only to employees. Transaction was substantiated with proper documentation and confirmations. Since assessee received funds as interest-free loan with no obligation to pay interest, AO's suo-moto calculation of notional interest was unjustified and without legal basis. CIT(A)'s deletion of addition was upheld. en-us Thu, 20 Mar 2025 00:00:00 +0530 Thu, 03 Apr 2025 07:50:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768224 ITAT Mumbai dismissed revenue's appeal regarding notional interest addition on Rs. 30 crores interest-free loan received by assessee from RPTPL under pre-emption rights agreement dated 26/10/2016. AO incorrectly applied Rule 3(7)(i) for calculating notional interest, which applies only to employees. Transaction was substantiated with proper documentation and confirmations. Since assessee received funds as interest-free loan with no obligation to pay interest, AO's suo-moto calculation of notional interest was unjustified and without legal basis. CIT(A)'s deletion of addition was upheld. Case-Laws Income Tax Thu, 20 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768224