ITAT Pune bench has held that the notional rental addition

 ITAT Pune bench has held that the notional rental addition

ITAT Pune bench has held that the notional rental addition could not be made regarding the residential assets included in stock-in-trade because section 5 of the Act clearly stipulates that a person who is a resident can be subjected to tax in respect of income from whatever source which is received or is deemed to be received in India or accrues or arises or deemed to accrue or arise to him in on outside India during such year. As the instant imaginary income charged to tax by the AO is neither a deemed income under the head 'Business income’ nor is received or deemed to be received or accruing or arising or deemed to accrue or arise, not falling in any of the categories given in clauses (a) to (c) of section 5(1).( ITA No’s.110 to 112/PUN/2018)



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