Allowing the appeal, the High Court observed that:

• Since loans were availed through proper banking channels and interest amounts were paid to lenders who had disclosed same in their respective tax returns and tax was remitted by them on such interest income; and
• It may be true that the earlier assessments stood concluded upon intimation being issued under section 143(1) of the Act and in none of the years, there was an assessment u/s 143(3), however, the assessments for the previous years had not been disturbed by the Revenue (either u/s 143(3) or reopening u/s 148). Therefore, the assessments could not have been brushed aside and an attempt ought to have been made to examine the genuineness of the stand. Hence, impugned disallowance was unjustified and matter was to be remanded. [TCA No.744 of 2019, dt. 05-10-2020] (AY. 2011 -12)