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TMI Blog2022 (5) TMI 1585X X X X Extracts X X X X X X X X Extracts X X X X ..... LD THAT:- As per Section 57(iii) of the Act, any expenditure not being in the nature of a capital expenditure, laid out or expended wholly and exclusively for the purpose of making or earning income under the head 'income from other sources' is to be allowed as a deduction. As the interest-bearing unsecured loans were raised by the assessee with a purpose, intent and motive of earning inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ember And Shri Rathod Kamlesh Jayantbhai, Accountant Member For the Assessee : None. For the Revenue : Shri G. N. Singh, DR. 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 T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssary details, the assessee had raised interest bearing unsecured loans, on which, interest of Rs. 6,45,531/- was paid by him. The aforesaid interest bearing borrowed 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 i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er Rule 24 of the Appellate Tribunal Rules, 1962, i.e, after hearing the respondent revenue and perusing the orders of the lower authorities. 6. We have heard the 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... duction of interest expenditure of Rs.6,45,531/-, as claimed by the assessee, and rightly so, was duly allowable as a deduction u/s. 57(iii) of the Act. We, thus, in terms of our aforesaid observations not finding favor with the view taken by the lower authorities set-aside the order of the CIT(Appeals) and vacate the disallowance of Rs. 6,45,531/- made by the A.O. Thus, the Grounds of appeal No.( ..... X X X X Extracts X X X X X X X X Extracts X X X X
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