Interest Income from Loans is Business Income; Consistent Tax Treatment Required if No Change in Circumstances.

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....Correct head of income - treatment of interest income - The activity of advancing loans, in such a case, would become assessee’s business and naturally, the interest earned thereupon would constitute Business Income for the assessee. - The rule of consistency would demand that their being no change in facts or circumstances, the accepted position should not be disturbed. - AT....