JUDGMENT : M.R. Shah, J. 1. Feeling aggrieved and dissatisfied with the impugned judgment and order dated 26.02.2016 passed by the learned Income Tax Appellate Tribunal, "C" Bench, Ahmedabad in ITA No. 64/AHD/2013 for AY 2008-09, the Revenue has preferred the present Tax Appeal with the following proposed question of law. "Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance of interest expenses of Rs. 48,74,798/-? 2. The facts leading to the present appeal in nutshell are as under: 2.1. That the assessee filed its return of income for AY 2008-09 declaring total income at Rs. 46,02,780/-. That the Assessing Officer framed the scrutiny assessment under Section 143(3) of the Act on 16.12.2010 determining total income at Rs. 2,00,31,830/-, after making following additions. Particulars Amount (Rs.) Investment in purchase of land at Adalaj 74,50,000/- Disallowance of Interest 73,05,794/- Disallowance u/s. 14 A of the Act 6,73,251/- 2.2 Feeling aggrieved and dissatisfied with the order of assessment in making additions on investment in purchase of land at Adalaj at Rs. 74,50,000/-; making Disallowance of Interest at Rs. 73,05,794/- and making Disallowance u/s. 14 A of the Act at Rs. 6,73,251/-, the assessee preferred appeal before the learned CIT(A). The learned CIT(A) deleted the addition made by the Assessing Officer on account of investment in purchase of the land at Adalaj of Rs. 74,50,000/- and confirmed the disallowance of interest of Rs. 48,74,798/- out of total interest disallowance of Rs. 73,05,794/- and deleted the balance interest expenses of Rs. 24,30,996/-. 2.3. Feeling aggrieved and dissatisfied with the order passed by the learned CIT(A) in confirming the disallowance of interest of Rs. 48,74,798/-, the assessee preferred appeal before the learned Tribunal being ITA No. 64/AHD/2012 for AY 2008-09. That by impugned judgment and order, the learned Tribunal has deleted the disallowance of interest of Rs. 48,74,798/- also. 2.4. Feeling aggrieved and dissatisfied with the impugned judgment and order passed by the learned Tribunal in deleting disallowance of interest of Rs. 48,74,798/- also, the Revenue has preferred present Tax Appeal with the following proposed question of law. "Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance of interest expenses of Rs. 48,74,798/-? 3. We have heard Shri Manish R Bhatt, learned counsel for the Revenue and Shri S.N. Divatia, learned advocate for the assessee. 48,74,798/- also, the Revenue has preferred present Tax Appeal with the following proposed question of law. "Whether the Appellate Tribunal has erred in law and on facts in deleting the disallowance of interest expenses of Rs. 48,74,798/-? 3. We have heard Shri Manish R Bhatt, learned counsel for the Revenue and Shri S.N. Divatia, learned advocate for the assessee. Having heard the learned advocates for the respective parties and considering the order passed by the learned CIT(A) as well as learned Tribunal, it appears that the assessee advanced substantial amount to M/s. RJD Impex Pvt. Ltd. for the purpose of business on charging interest. The Assessing Officer was of the opinion that interest charged was at a lower rate and therefore, he made the addition of Rs. 73,05,794/-. The learned CIT(A) granted partial relief to the extent of Rs. 24,30,996/-. On an appeal, the learned Tribunal has given full relief by deleting the disallowance of interest of Rs. 73,05,794/-, by observing in para 11 to 13 as under: "11. Neither the AO nor the First Appellate Authority have brought any cogent material on record which could demonstrate that M/s. RJD Impex Pvt. Ltd. has not used the money for its business. The detailed explanation filed by the assessee regarding land dealings has been rubbished by the First Appellate Authority without any demonstration. 12. Once it is established that there is nexus between expenditure and the purpose of business "which need not necessarily be the business of the assessee itself, the revenue cannot justifiably claim to put itself in the arm chair of businessman or in position of Board of Directors and assume role to decide how much is reasonable expenditure having regard to the circumstances of case. No businessman can be compelled to maximize his profit and that the revenue authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act. The authorities must not look at the matter from their own view point but that of a prudent businessman. These observations are given by the Hon'ble Supreme Court in the case of Hero Cycles (P) Ltd. 63. Taxmann. Com 308 or 281 CTR 481. 13. The authorities must not look at the matter from their own view point but that of a prudent businessman. These observations are given by the Hon'ble Supreme Court in the case of Hero Cycles (P) Ltd. 63. Taxmann. Com 308 or 281 CTR 481. 13. Considering the fact that assessee has made land business profit of 5.45 crores in the light of the ratio laid down by the Hon'ble Supreme Court (supra), we do not find any merit in making the addition of Rs. 48,74,798/- on account of loss of interest @ 6% we accordingly set aside the findings of the learned CIT(A) and direct the AO to delete the addition of Rs. 48,74,798/-." 4. Considering the fact that the assessee established nexus between the expenditure and the purpose of business as rightly observed by the learned Tribunal, it was not open for the Assessing Officer to assume the role to decide how much reasonable expenditure. Under the circumstances, it cannot be said that the learned Tribunal has committed any error in deleting entire disallowance of interest of Rs. 73,05,794/-. We are in complete agreement with the view taken by the learned Tribunal. We see no reason to interfere with the impugned judgment and order passed by the learned Tribunal in deleting disallowance of interest of Rs. 73,05,794/-. (Learned Tribunal has deleted disallowance of interest of Rs. 48,74,798/- as such learned CIT(A) granted partial relief and deleted the interest expenses of Rs. 24,30,996/-). No substantial question of law arise in the present Tax Appeal. Hence, present Tax Appeal deserves to be dismissed and is accordingly dismissed.