Vinayak Kalani v. DCIT (2024) 209 ITD 501 (Indore)(Trib.)

S. 57 : Income from other sources-Deductions-Interest income-Burden is on assessee-Burden is on assessee to provide sufficient details to show that expenses were incurred wholly and exclusively for purpose of making or earning interest income.[S. 56, 57(iii)]

Assessee-individual declared loss of certain sum under head Income from other sources.  Assessing Officer completed assessment by making disallowance of deductions claimed under section 57. CIT(A) up held the order off the AO. On appeal the Tribunal held that  in terms of legal provision of section 57(iii), deductions claimed by assessee are allowable only if relevant expenses have been laid out or expended wholly and exclusively for purpose of making or earning interest income.  Since deduction claimed by assessee under section 57(iii) was about 2.68 times of interest income and, thus, there was a wide gap, it was assessee’s burden to provide sufficient details to show that expenses were incurred wholly and exclusively for purpose of making or earning interest income. Since Assessing Officer disallowed interest deduction claimed by assessee fully as if assessee had not utilized a single pie of borrowed funds for giving loans, approach of Assessing Officer was also not correct. Matter is remanded back to file of Assessing Officer for a fresh adjudication. (AY. 2020-21)