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    <title>2025 (4) TMI 1435 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad allowed the assessee&#039;s appeal regarding deduction of interest expenditure under section 57(iii) against interest income from loans and advances. The tribunal found that the assessee had sufficiently established nexus between interest-bearing borrowings and interest-earning advances through documentary evidence. The AO and CIT(A) had disallowed the deduction without pointing out specific defects in the evidence. The tribunal emphasized that disallowance cannot be sustained on mere conjecture or suspicion. Additionally, noting that similar deduction was allowed in the subsequent assessment year 2018-19, the tribunal applied the consistency principle and directed deletion of the disallowance.</description>
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    <pubDate>Wed, 23 Apr 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 1435 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=769521</link>
      <description>ITAT Ahmedabad allowed the assessee&#039;s appeal regarding deduction of interest expenditure under section 57(iii) against interest income from loans and advances. The tribunal found that the assessee had sufficiently established nexus between interest-bearing borrowings and interest-earning advances through documentary evidence. The AO and CIT(A) had disallowed the deduction without pointing out specific defects in the evidence. The tribunal emphasized that disallowance cannot be sustained on mere conjecture or suspicion. Additionally, noting that similar deduction was allowed in the subsequent assessment year 2018-19, the tribunal applied the consistency principle and directed deletion of the disallowance.</description>
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