TMI Blog2021 (3) TMI 1354X X X X Extracts X X X X X X X X Extracts X X X X ..... - X X X X Extracts X X X X X X X X Extracts X X X X ..... ured loans taken by him from different parties. In addition, the assessee has also paid interest for Rs. 13,40,951/- on loan against property from Axis Bank Ltd. Thus, total interest paid by the assessee during the F.Y. 2015-16was Rs. 47,93,935/- (Rs. 34,52,984/- plus Rs. 13,40,951/-). However, the Ld. AO made complete disallowance of the interest paid of Rs. 47,93,935/- which was claimed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee has been continued since many years. The lower authorities, accepting the said activity of the assessee have never made any addition on this issue in the earlier assessment years as well as in the subsequent year except the assessment year under consideration. The Ld. Counsel has further submitted that though, some part of the loans amounting to Rs. 13,40,951/- was taken from Bank aga ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the Department that the interest bearing funds have been used by the assessee for some other purposes. 5. The Ld. D/R has relied upon the findings of the lower authorities. 6. We have considered the rival contents. The assessee has demonstrated from the record that the activity of the assessee of taking interest bearing loan and making advances to other parties is continued for the last so m ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee and the net of the same has rightly been offered by the assessee for taxation. In view of above discussion, the addition made by the Assessing Officer is ordered to be deleted. The ld. Representative parties have submitted that the facts and issues involved in all the captioned appeals the identical. In view of our findings given above, the addition made by the lower authorities in all t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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