The assessee borrowed money for the purpose of business-Keeping in mind utilisation of funds lying idle with them, assessee lent a sum of Rs. 17 crores to ABW Infrastructure at same rate of interest as was paid. Interest income was shown as income from other sources and interest paid was claimed as expenditure. The AO disallowed the interest expenditure, which was affirmed by the CIT (A). On appeal the Tribunal held that   transactions were driven by business considerations and were part of commercial expediency, disallowance of interest expense on loan taken for purposes of business against which interest income had been earned and offered to tax, was unwarranted and same qualified to be allowed under section 36(1)(iii)/section 37(1). Tribunal also held that even in alternative, such an expense qualified as a deduction under section 57(iii) against interest income offered to tax, being an expenditure incurred in relation to earning of interest income on loan taken from one company and then given to another.  Referred, S.A. Builders Ltd v. CIT (2007) 288 ITR 1 (SC), Madhav Prasad Jatia v.CIT (1979) 118 ITR 200 (SC), CIT v. Malayalam Plantations Ltd (1964) 53 ITR 140(SC). (AY. 2013-14)