Classification of large unsecured loan interest as business income; deduction disallowed u/s40(a)(ia) and audit required u/s44AB

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....Classification of interest on large unsecured loans as business income was affirmed by applying the definition of business and principles of consistency: systematic borrowing, intermediation through brokers, profit motive and attendant business risks constituted business activity, leading to treatment of interest as business receipts. Consequentially, deduction for such interest was disallowed due to failure to deduct tax at source, and the taxpayer was held liable to maintain audit under statutory audit provisions because business receipts exceeded the prescribed threshold.....