On request from the borrower Le. DJ (P) Ltd., the assessee waived off its right of interest on CCDs on 31st March, 2015 for bona fide commercial expediency. DJ (P) Ltd. did not have the income or financial capacity to pay the interest and there was no hope of recovery which is evident from its audited financial statements as on 31st March, 2015. The AO assessed the interest on notional basis. CIT(A), affirmed the order of the AO. On appeal the Tribunal held that  the interest so waived cannot be said to be accrued to the assessee warranting taxation of the same-In any event, there is no provision in the Act to bring to tax notional interest income. Addition is deleted. Followed,  CIT v. Shoorj Vallabhdas & Co. (1962) 46 ITR 144 (SC), Shivlaxmi Exports Ltd. vs. CIT (2017) 81 taxmann.com 262 (Cal)(HC)  and Shiv Nandan Build Con (P) Ltd. vs. CIT (2015) 60 taxmann.com 347 (Delhi)(HC).  (AY.2015-16)