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ITAT allowed the assessee's appeal and directed that the deduction claimed under sec.57 be permitted. The Tribunal held that the AO erred in denying the deduction by overlooking that the interest income arose from surplus funds in the assessee's savings account and fixed deposits funded by loan proceeds, and that the requisite nexus between expenditure and income was established. The Tribunal rejected the AO's contention that rotational loan movements within the partnership vitiated the claim, finding no disallowance warranted on that basis. The relief was granted on the specific factual matrix of the case, the Tribunal emphasising that its view is confined to these peculiar facts and is not to be treated as a precedent.
ITAT allowed the assessee's appeal and directed that the deduction claimed under sec.57 be permitted. The Tribunal held that the AO erred in denying the deduction by overlooking that the interest income arose from surplus funds in the assessee's savings account and fixed deposits funded by loan proceeds, and that the requisite nexus between expenditure and income was established. The Tribunal rejected the AO's contention that rotational loan movements within the partnership vitiated the claim, finding no disallowance warranted on that basis. The relief was granted on the specific factual matrix of the case, the Tribunal emphasising that its view is confined to these peculiar facts and is not to be treated as a precedent.
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