Notional interest on slump sale balance deleted as commercially expedient arrangement, with consistency in revenue treatment supporting the assessee.

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....The ITAT held that an outstanding balance taken over under a Business Transfer Agreement in a slump sale could not be treated as an interest-free advance to a group company for making a deemed interest addition. It accepted that the amount was not an actual loan from borrowed funds but part of a commercially expedient business arrangement, and also relied on the Revenue's consistent acceptance of the same position in later years. The Tribunal further found that a larger notional disallowance was untenable where the actual interest debited in the year was minimal. The impugned addition was deleted and income was directed to be recomputed accordingly.....