The assessee was engaged in the business of running a hotel and made investments in V Hotels. It borrowed funds from a co-operative bank for the purpose of making investments in V Hotels. He declared interest from other sources and claimed deduction of the interest paid on unsecured loans and on bank loans and set off the resultant loss against the income from other sources, business and capital gains under S. 71 of the Act.  which the AO.  The CIT(A) deleted the disallowance.  On appeal  the Tribunal held that  the assessee had borrowed the funds and made investments in the business. The AO  did not make out a case that the assessee had diverted the funds for non-business purpose.  Business consideration was the decision of the assessee and not the AO.  The assessee made the investments for the purpose of business and paid the interest.  The income under the head “Income from other sources” resulted in a loss which was claimed for set off under section 71.  Intra head losses were allowable to be set off against other sources of income in the same assessment year.  Therefore the addition was deleted.  (AY.   2012-13  2013-14).