2021 (2) TMI 1383

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..... Prasad For the Revenue : Shri Sunil Kumar Pandey, DR ORDER PER A. MOHAN ALANKAMONY, AM. Both the appeals are filed by the assessee against the orders of the Ld. CIT (A)-1, Guntur in appeal No. 219 and 104/CIT(A1)/Gnt/2015-16 & 2016-17, both dated 14/2/2018 passed U/s. 143(3) r.w.s 250(6) of the Act for the AYs 2012-13 and 2013-14 respectively. 2. The assessee has raised four groun....

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....posits on the ground that the deposits were made from surplus funds. 2. The Ld. CIT (A) has erred in confirming the order of the ld. AO who had denied the claim of deduction towards interest payable on borrowed funds while computing the taxable interest income earned by the assessee on the fixed deposits made from the borrowed funds. 4. The brief facts of the case are that the assessee....

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....e outset, we do not find any merit in the orders of the Ld. Revenue Authorities in this regard. In the case of the assessee the decisions relied by the Ld. Revenue Authorities have no application. The facts in the case of the assessee are that it has borrowed funds from the bank for the purpose of its business. Since the entire funds could not be utilised during the relevant AYs the same were plac....

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....rdance with section 57(iii) of the Act. Accordingly, the concise Ground of the appeal in ITA No. 1263/H/2018 for the AY 2012-13 and the concise Ground No.2 of the appeal in ITA No. 1264/H/2018 for the AY 2013-14 are disposed off. 6. With respect to the first concise Ground of the appeal in ITA No. 1264/H/2018 for the AY 2013-14, it is obvious that if the assessee has deposited its surplus funds....