2014 (1) TMI 384

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....DER PER D. MANMOHAN, V.P. 1. These appeals by the Revenue pertain to the assessment years 2005-2006 and 2006-2007. Since the issue involved in both the appeals is identical we proceed to dispose of the appeals by a common order for the sake of convenience. Grounds raised by the Revenue are extracted for immediate reference.      1. The Order of the CIT(A) is opposed to....

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....he time of hearing, the decision of the CIT(A) may be set aside and that of the Assessing Officer be restored." 2. Admittedly, Assessing Officer sought to bring to tax notional interest income on the ground that the assessee ought to have charged interest at 12% on the loans advanced to various parties. The case of the assessee was that the amounts were advanced in the course of its business an....

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....ssessee is not connected to the business carried on by the assessee. 3. On an appeal filed by the assessee, the learned CIT(A) observed that the assessee had justifiable reasons for advancing the amounts in its capacity as a prudent businessman. At any rate, notional interest cannot be added to the taxable income. In fact, the Assessing Officer has not added any notional income but merely sough....