Allowing the appeal of the assessee the Tribunal held that, notional interest on security deposit from lessee  cannot be taxed  even during the period when the property was sold but the deposit continued with the lessee as the lease agreement had lock -in -clause . Tribunal held that in order to tax any amount , the revenue has to prove that the amount has indeed earned by the assessee.  Only the  incomes which fall under the deemed provisions which have been explicitly mentioned in the act can be brought to tax under the deeming provisions but not any other notional or hypothetical income not envisaged by the Act.    ( ITA No. 300/ Delhi/ 2020 dt 3-6 -2020 ) (AY. 2017 -18)