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    <title>2025 (8) TMI 688 - ITAT DELHI</title>
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    <description>ITAT Delhi held that notional interest on loans and advances cannot be taxed as income under the Act, affirming that only actual income is taxable. The addition of notional interest was deleted following established Supreme Court precedent. Regarding the addition under section 41(1) read with section 28(iv) for loan and interest written off, the AO failed to produce evidence of waiver or proper inquiry into conflicting confirmations from the creditor. The creditor had recognized the loan as a capital liability and sought recovery, negating the applicability of section 41(1). The tribunal upheld the CIT(A)&#039;s decision dismissing the Revenue&#039;s grounds, thereby rejecting the additions made by the AO.</description>
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    <pubDate>Wed, 06 Aug 2025 00:00:00 +0530</pubDate>
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      <title>2025 (8) TMI 688 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=776501</link>
      <description>ITAT Delhi held that notional interest on loans and advances cannot be taxed as income under the Act, affirming that only actual income is taxable. The addition of notional interest was deleted following established Supreme Court precedent. Regarding the addition under section 41(1) read with section 28(iv) for loan and interest written off, the AO failed to produce evidence of waiver or proper inquiry into conflicting confirmations from the creditor. The creditor had recognized the loan as a capital liability and sought recovery, negating the applicability of section 41(1). The tribunal upheld the CIT(A)&#039;s decision dismissing the Revenue&#039;s grounds, thereby rejecting the additions made by the AO.</description>
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      <pubDate>Wed, 06 Aug 2025 00:00:00 +0530</pubDate>
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