https://www.taxtmi.com/caselaws?id=797599 Interest received from loans advanced to companies is taxable under Income from Other Sources where no agency or management contract, or termination or modification of such contract, supports assessment under Section 28(ii)(a). Although lending may be viewed as an adventure in the nature of trade, the stated basis of assessment cannot be replaced at the appellate stage with a different general basis under Section 28. Interest paid on borrowed funds used to make the interest-bearing advances is deductible under Section 57(iii) when a reasonable and proximate nexus with the income earned is established. The Explanation to Section 37(1) does not govern expenditure once the related income is assessed under Income from Other Sources. en-us Thu, 20 Aug 2026 00:00:00 +0530 Tue, 25 Aug 2026 08:34:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797599 Interest received from loans advanced to companies is taxable under Income from Other Sources where no agency or management contract, or termination or modification of such contract, supports assessment under Section 28(ii)(a). Although lending may be viewed as an adventure in the nature of trade, the stated basis of assessment cannot be replaced at the appellate stage with a different general basis under Section 28. Interest paid on borrowed funds used to make the interest-bearing advances is deductible under Section 57(iii) when a reasonable and proximate nexus with the income earned is established. The Explanation to Section 37(1) does not govern expenditure once the related income is assessed under Income from Other Sources. Case-Laws Income Tax Thu, 20 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797599