ACIT v. Ashok Radhakishen Mehra (2021) 188 ITD 663/ 86 ITR 19 (SN) (Mum.)(Trib.)

S. 43B : Deductions on actual payment-Interest payable to Bank-Provision that conversion of interest into loan not equivalent to actual payment-Payment through overdraft account or cash credit account-Not disqualified. [S. 43B(d), 43B(e)]

Dismissing the appeal the Tribunal held that as the interest amount paid by the assessee through overdraft or cash credit account was not similar to loan accounts, thus, Explanation 3D to section 43B would not be applicable in so far the interest amount had been actually paid by the assessee through overdraft or cash credit account and had not been converted into loan or advance. (AY. 2015-16)