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    <title>2026 (5) TMI 1476 - ITAT DELHI</title>
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    <description>An addition for deemed notional interest on an outstanding balance in the name of a group company was unsustainable because the balance arose from a business transfer agreement under which the assessee had taken over the assets and liabilities of the transferred undertaking, not from an actual loan advance. The amount had been carried forward consistently from earlier assessment years and accepted in scrutiny assessments without any interest disallowance. The record also showed that the year&#039;s actual interest expenditure was well below the notional addition, undermining the estimate. The addition was deleted and the issue was decided in favour of the assessee.</description>
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