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    <title>2026 (7) TMI 1725 - GUJARAT HIGH COURT</title>
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    <description>Notional interest cannot be assessed on outstanding balances under the mercantile system unless interest income has actually accrued. Despite the general accrual principle, the concerns had not paid interest for two years, one had ceased operations and the other had been wound up, and no recoveries were made. Their relationship with the assessee&#039;s partners did not by itself establish deliberate waiver of interest or accrual of income. The notional-interest addition was therefore unsustainable and deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795839</link>
      <description>Notional interest cannot be assessed on outstanding balances under the mercantile system unless interest income has actually accrued. Despite the general accrual principle, the concerns had not paid interest for two years, one had ceased operations and the other had been wound up, and no recoveries were made. Their relationship with the assessee&#039;s partners did not by itself establish deliberate waiver of interest or accrual of income. The notional-interest addition was therefore unsustainable and deleted.</description>
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