Only TDS Component Taxable When Assessee Acts as Facilitator; Section 57 Disallowance Partly Deleted

Bharath Bail Vs DCIT (ITAT Bangalore) The assessee arranged borrowings of ₹1.77 crore for a company, where funds were directly advanced by lenders to the company and interest was also paid directly by the company to the lenders. However, TDS on interest (₹2.04 lakh) was deducted in the assessee’s name, and he offered the gross interest income (₹20.49 lakh) to tax while claiming equal deduction under Section 57. The AO disallowed the deduction due to lack of proof of actual interest payment by the assessee, which was upheld by the CIT(A). The ITAT observed that the assessee merely acted...