Expenditure Against Interest Income Allowable u/s 57 or 37, Depending on Income Category Per Sections 56 or 28.

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....Claim of expenditure against interest Income - Since, we hold in principle that the expenditure is allowable either way u/s 57, if the income is treated under the head “income from other sources” as per the provisions of Section 56 or u/s 37, if the income is treated under the head “profits and gains of business or profession” as per the provisions of Section 28, at this juncture, we refrain from determining issue of the claim of preclusion or collateral estoppel under “which head” the income earned by the assessee is taxable. - AT....