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TMI Blog2024 (10) TMI 746X X X X Extracts X X X X X X X X Extracts X X X X ..... e very same query was raised by the AO vide notice u/s 142(1) - assessee filed a reply proving one to one nexus thereon. AO on being satisfied with the same completed the assessment for the AY 2016-17 u/s 143(3) on 30.11.2018 granting deduction for interest paid to Allahabad Bank while computing income from other sources. The very same claim for a different figure is being made in the year under c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TBA/NFAC/S/250/2023-24/1056772490(1) dated 04.10.2023 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the Act ) dated 30.10.2019 by the Assessing Officer, NFAC, Delhi (hereinafter referred to as ld. AO ). 2. Though the assessee has raised several grounds before us, the only effective issue to be decided in this appeal is as to whether the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee earned an interest income of Rs. 52,97,393/- from the said company on the loan advanced to them. This interest income was declared as income by the assessee under the head income from other sources . Since borrowed money was utilized directly for advancing loan to the aforesaid company, the assessee claimed interest payment made to Allahabad Bank as deduction u/s 57(iii) of the Act in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is no requirement for the assessee to prove the nexus between borrowed funds and its utilization as it had already been proved by the assessee in AY 2016-17 and accepted by the revenue. Accordingly, we hold that the assessee would be eligible for deduction of interest paid to Allahabad Bank u/s 57(iii) of the Act. Accordingly, the grounds raised by the assessee are allowed. 4. In the result, the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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