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    <title>2026 (9) TMI 1694 - ITAT DELHI</title>
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    <description>Tax-deduction disallowance on interest does not arise where no interest is credited or paid in the relevant year; brought-forward closing balances alone do not trigger withholding. Section 69C applies only to unexplained expenditure incurred during the relevant financial year, so a recorded capital advance paid through banking channels in an earlier year cannot be treated as fresh unexplained expenditure merely because it remains in the balance sheet. Amounts already added back as capital write-offs cannot be added again. Notional interest is not taxable where no real income accrued, and project-interest disallowance fails where tax was deducted and deposited within the prescribed time. The additions and disallowances were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=799668</link>
      <description>Tax-deduction disallowance on interest does not arise where no interest is credited or paid in the relevant year; brought-forward closing balances alone do not trigger withholding. Section 69C applies only to unexplained expenditure incurred during the relevant financial year, so a recorded capital advance paid through banking channels in an earlier year cannot be treated as fresh unexplained expenditure merely because it remains in the balance sheet. Amounts already added back as capital write-offs cannot be added again. Notional interest is not taxable where no real income accrued, and project-interest disallowance fails where tax was deducted and deposited within the prescribed time. The additions and disallowances were deleted.</description>
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