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Section 4 of the Income Tax Act, 1961—Income - In order to tax any amount, the revenue has to prove that the amount as indeed been earned by the assessee and only the incomes fall under the deemed provisions which have been explicitly mentioned in the Income Tax Act can only be brought to tax under the deeming provision but not any other notional or hypothetical income not envisaged by the Act, therefore, it was directed that the addition made by AO on account of notional income on the security deposit cannot be held to be legally valid. - HARVANSH CHAWLA V/s ASSTT. CIT -  82 ITR (TRIB) 160 (ITAT-DELHI)