“Section 57(1)(iii)”
The decision most relied on for Section 57(1)(iii) is CIT v. Rajendra Prasad Moody (115 ITR 519), cited in 386 judgments on BharatTax.
Leading authorities on Section 57(1)(iii)
For deductions under Section 57(iii) relating to "Income from Other Sources," an expenditure is allowable if it is laid out wholly and exclusively for the purpose of making or earning such income, even if no income is actually earned in that previous year.
For computing the deduction under Section 80M, only the net dividend income (gross dividend income after reducing expenses attributable to earning it, as per Section 57(iii) and the principle in Section 80AB) is eligible. The case also holds that tax authorities are not bound to perpetuate an error from a previous assessment year, as each year is a separate unit and consistency cannot override substantive justice.
Income derived from letting out property along with incidental use of furniture, fixtures, and common facilities is assessable as 'income from house property' and not 'business income' when the prime object is merely to let out and not to exploit the property as a business asset.
When a co-operative society earns interest on deposits with scheduled banks, this income is assessable under "Income from other sources" (Section 56), and the society is entitled to deduct related administrative and proportionate expenses under Section 57 to tax only the net interest income.
Income arising from mutual activities carried out by clubs or associations solely among their members is not assessable for income tax, as it does not constitute income from a trade or business due to the principle of mutuality.
Interest paid on a loan taken against the security of a fixed deposit cannot be set off against or reduced from the interest income earned on that fixed deposit. The Income-tax Act does not permit such netting.
This case establishes that merely having sufficient interest-free own funds does not automatically prevent interest disallowance on interest-free advances; the assessee must affirmatively prove the business or commercial expediency of such advances.
The nature of the activity giving rise to income is fundamental in determining the deductibility of expenses. Interest on loans for acquiring properties held as current assets is a deductible business expenditure if incurred for business purposes.