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Income Tax - Highlights / Catch Notes

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Accrual of income - Taxability of notional interest income ...


Interest-Free Loans to Subsidiaries Not Taxable Income, Rules Appellate Tribunal; Notional Interest Excluded from Taxes.

April 6, 2024

Case Laws     Income Tax     AT

Accrual of income - Taxability of notional interest income credited by the assessee in his profit and loss account as per the requirement of Indian Accounting Standards - The assessee, a public limited company, had credited interest-free loans to its subsidiary and accounted for "notional interest" in its books. The Revenue challenged this, arguing for its inclusion in taxable income. However, the Appellate Tribunal, after considering submissions from both sides and referring to relevant precedent, ruled in favor of the assessee. It held that since there was no contractual obligation for the debtor to pay interest, the notional interest income did not accrue and should not be taxed.

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