When no interest is received same cannot be taxed on hypothetical basis

If there was funds available both, interest-free and overdraft and or/loans taken, then a presumption would arise that investments would be out of the interest-free funds generated or available with the company, if the interest free funds were sufficient to meet the investments. In the present case, there sufficient interest free funds were available at the disposal of the assessee.

ITAT held that that if interest income does not result at all, there cannot be any tax and that if an income has not materialized, then m

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