2014 (6) TMI 141

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....red in holding that interest income of Rs.40,29,664/- is taxable as income from business and not as income from other sources as held by the Assessing Officer, overlooking the fact that the assessee has not carried on any business activity during the previous year and money lending is not incidental to the main business of the assessee namely export-import of goods. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in holding that expenses to the extent of Rs.18,37,957/- disallowed by the Assessing Officer should be allowed as deduction from the interest income of Rs.40,34,664/- despite evidence on record indicating that the above expenses are not allowable as they have not been shown to be incurred to....

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....the assessee and the expenditure incurred by the assessee in relation to its export-import business was allowable to be deducted out of the said income. Aggrieved against the order of the ld. CIT(A) the Revenue has thus come into appeal before us. 4. We have heard the ld. representatives of both the parties and also have gone through the records. The ld. A.R. of the assessee has submitted that though no activity relating to export-import business of the assessee was made during the year, however, money was lent to the sister concern out of the business expediency. One of the objects of the company was also to lend the money. He has further submitted that the expenditure was relating to director's remuneration which was incurred for survi....