Best Trading and Agencies Ltd. v. Dy.CIT (2020) 428 ITR 52 / 275 Taxman 550/ ( 2021 ) 203 DTR 269/ 321 CTR 373 (Karn.)(HC)

S. 57 : Income from other sources-Deductions-Fixed deposits- Interest payment for earning income is held to be deductible. [S. 56, 57(iii)]

Allowing the appeal of the assessee the Court held that in order to cover the cost of interest payable to the creditors for the unpaid period, invested the surplus in fixed deposits and earned interest. The amount earned by way of interest was paid to the lenders and creditors. There was a nexus between the interest paid to the creditors on the unpaid balance and interest earned on the deposits. The interest expenditure was incurred wholly and exclusively for the purpose of earning the interest income and therefore, the assessee was entitled to deduction of the interest income under section 57(iii). (AY. 2005-06, 2006-07)