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Judgment
This assessee’s appeal for Assessment Year 2018-19 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1081748523(1) dated 14.10.2025, in proceed ings u/s 143(3) of the Income Tax Act, 1961 (in shor t “the Act”).
Heard both the p arties at length. Case file perused.
Coming to the assessee’s sole substantive ground raised herein, a perusal of the case file indicates that bo th the learned lower authorities have restricted his interest expenditure claim u/s 57(iii) of the Act fo r the sole reason that since he is a director in M/s Shamsons Polymers (P) Ltd. and had availed interest bearing loans facility from M/s HSBC Bank whereas the realization o f interest there upon from the company happens to be only @ 6%. It is in this factual backdrop that both the learned lower authorities are of the co nsidered view that the assessee is not entitled for the differential rate of interest @3.4% as deduction against his interest income u/s 57(iii) of the Act. They have disallowed the same in assessment order dated 12.03 .2021 as up held in the lower appellate discussion in other words.
Faced with this situation, it is noticed that the tribunal in Mahendra Singh Meel Vs. ITO , IT A No. 55/JP/2018 decided on 29.10.2019 has already settled the issue that the impugned section 57( iii) interest expenditure claim could not be limited only to the exte nt of the interest income received or realized thereupon; as the case may be. I accordingly delete the impugned disallowance in very terms.
No other ground or argument has been pressed.
This assessee’s appeal is allowed.