2022 (5) TMI 1585

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....ORDER PER RAVISH SOOD, JM: The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals)-1, Raipur (C.G.) dated 30.05.2018, which in turn arises from the order passed by the A.O under Sec. 143(3) of the Income Tax Act, 1961 (for short 'the Act'), dated 23.02.2016 for assessment year 2013-14. Before us the assessee has assailed the impugned order on the follo....

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....orrowed funds were channelized by the assessee for advancing of interest-bearing loans to various parties, on which, interest income of Rs.6,40,874/- was received by him. Qua the aforesaid facts, the assessee had sought for setting-off the interest paid on the borrowed funds against the aforesaid interest income so received by him. However, the AO was not persuaded to subscribe to the aforesaid cl....

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.... ld. Departmental Representative ("DR", for short), perused the orders of the lower authorities and the material available on record. After deliberating at length on the issue in hand we are unable to persuade ourselves to subscribe to the view taken by the lower authorities. As per Section 57(iii) of the Act, any expenditure not being in the nature of a capital expenditure, laid out or expended w....