Notional Interest & Deemed Dividend Addition for Debit Balance of Partners in Partnership Firm

Issue 1- Whether mere debit balance in partner’s capital A/c leads to addition on notional basis?

Facts – The facts of the case are that the assessee is a partnership firm and the Assessing Officer noticed that the debit balance in the partners’ account was more than the credit balance. He, therefore, charged the interest on the net debit balance of partners at the rate of 12% and accordingly made the addition of 20,61,845/-