Notional Interest on deposit not includible in “Annual Value” u/s 23(1)(a) & 23(1)(b)

In Circular 204 dated 24.7.1976, the CBDT has accepted that u/s 23(1)(a) the “sum for which the property might reasonably be expected to let from year to year” is the municipal valuation of the property. The same view that the Municipal valuation is the annual value u/s 23(1)(a) has been taken in CIT vs. Prabhabati Bansali 141 ITR 419 (Cal) & M.V. Sonavala vs. CIT 177 ITR 246 (Bom);

The contrary view in Makrupa Chemicals 108 ITD 95 (Mum) & Baker Technical Services (P) Ltd 126 TTJ (Mumbai)(TM) 455 that annual value

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