Section 80V relief requires a proven link between borrowing and tax arrears payment; relief allowed only for post-loan payments.

Relief under section 80V depended on a borrowing being connected with payment of tax arrears. On the facts, the link was not proved for the earlier instalments because no material showed that the LIC loan was obtained specifically for those payments, so relief was denied for that part. The record did support the claim for tax payments made after receipt of the loan, so relief was allowed to that limited extent and the disallowance was set aside accordingly.

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Issues: Whether the assessee was entitled to relief under section 80V of the Income-tax Act, 1961 in respect of interest on the LIC loan used for payment of tax arrears, at least to the extent of tax payments made after receipt of that loan.

Analysis: Relief under section 80V depends on the borrowing being connected with payment of tax arrears. On the facts, the last two tax instalments fell due after the LIC loan was received and were paid thereafter. As no material was placed to show that the LIC loan was obtained specifically for the earlier two payments, the required connection could not be established for those amounts. However, the record supported the assessee's claim in relation to the tax payments made after receipt of the loan.

Conclusion: The assessee was entitled to relief under section 80V only in respect of the amounts paid after receipt of the LIC loan, and the disallowance was set aside to that limited extent.

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