Interest Expenditure Claim Acknowledged by AO; No Penal Action for Excess Disallowance Under Penalty 271(1)(c).

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....Penalty 271(1)(c) - deduction of interest out of ‘income from other sources’ - The AO has admitted the claim of interest expenditure to the extent of interest income and therefore one cannot definitely say that interest expenditure was not utilized for the purpose of earning interests - The disallowance of excess expenditure over and above similar income generated, cannot invite penal action in the form of penalty....