Notional Claims Against CPRPL Cannot Substitute Real Accrual for Tax

Vikram Bakshi and Company Pvt. Ltd. Vs CIT(A) (ITAT Delhi) No Notional Commission or Interest Taxable – CPRPL Never Paid or Accrued Any Amount; Only a Disputed Claim The Assessee, owner of commercial property at Mohan Dev Building, had entered into a management arrangement with Connaught Plaza Restaurants Pvt. Ltd. (CPRPL), later followed by a commission/lease agreement dated 15.03.2001. On 22.07.2002, the Assessee agreed to sell the property to CPRPL for ₹4.40 crore and received ₹4 crore advance. However, Noida Authority did not approve the transfer until FY 2019-20 due to title-rel...