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ITAT allowed the assessee's appeal, setting aside the disallowance of interest on loans under the head "income from other sources" made by the AO and sustained by NFAC. It held that, where no fresh loans were borrowed or advanced during the relevant year and only opening balances existed, the assessee was not required to re-establish a one-to-one nexus between interest paid and interest received under s.57(iii). As the nexus had already been accepted in earlier and subsequent years and full details of loans and interest were furnished, ITAT directed the AO to grant the claimed interest deduction.
ITAT allowed the assessee's appeal, setting aside the disallowance of interest on loans under the head "income from other sources" made by the AO and sustained by NFAC. It held that, where no fresh loans were borrowed or advanced during the relevant year and only opening balances existed, the assessee was not required to re-establish a one-to-one nexus between interest paid and interest received under s.57(iii). As the nexus had already been accepted in earlier and subsequent years and full details of loans and interest were furnished, ITAT directed the AO to grant the claimed interest deduction.
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