Tribunal held that, the Assessing Officer cannot disallow the interest on notional basis without proving that borrowed capital has been used for interest free advance or loan. (AY. 2011-12)
Unitech Ltd. v. DCIT (2019) 176 ITD 266 (Delhi)(Trib.)
S. 36(1)(iii) : Interest on borrowed capital–Interest free advances-Notional disallowance-Burden is on revenue to prove that borrowed capital has been used for interest free advance or loan-No disallowance can be made.