Interest Paid Deduction Upheld Despite AO’s Re-Examination

Surjeet Singh Vs ACIT (ITAT Agra)

No Fresh Loans, No Fresh Nexus—57(iii) Deduction Restored—AO Cannot Re-examine Nexus Every Year

Assessee, engaged in liquor business & partner in firms, declared interest income of Rs.1,17,97,996 & claimed interest expenditure of Rs.1,21,87,907, resulting in loss of Rs.8,89,911 under income from other sources. AO disallowed interest paid u/s 57(iii) on the ground that Assessee failed to prove one-to-one nexus between borrowed funds & loans advanced. NFAC upheld disallowance.<

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