Held allowing the appeal, that while the assessee’s contention that there could not be a one to one match between the loan used for investing in fixed deposits and for business was tenable, for the purpose of claiming deduction under section 57, the assessee had to establish that the expenditure (not being in the nature of capital expenditure) was laid out or expended wholly and exclusively for the purpose of making or earning such income. The Assessing Officer had not considered the movement in the loan account details submitted by the assessee nor considered the fresh fixed deposits and renewal of fixed deposits before concluding that the entire claim was not allowable under section 57. The alternate plea of the assessee that the interest expenditure if disallowed under section 57 should be allowed as business expenditure because the fixed deposits were kept for business purpose, had also not been considered by the authorities. The Assessing Officer was to consider the movement in the fixed deposit account and the loan account to understand the nexus and also to consider the alternate claim of interest as business expenditure based on the facts and evidence that may be submitted by the assessee. The assessee was to be given a reasonable opportunity of being heard. Matter remanded.(AY.2017-18, 2018-19)