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Issues: Whether the interest component awarded by the Motor Accident Claims Tribunal forms part of compensation as a capital receipt or is taxable as income from interest.
Analysis: Compensation awarded under the Motor Vehicles Act for death or injury is not income, but a capital receipt meant to restore the claimant to the pre-loss position. The interest awarded by the Tribunal is tied to the compensation award and compensates for delay in adjudication; until receipt under the award, it partakes the same character as the compensation itself. Section 171 of the Motor Vehicles Act, 1988 authorises such interest as part of the claim award, and the carve-out in Section 194A(3)(ix) of the Income-tax Act, 1961 indicates that the tax treatment turns on interest after receipt by the claimant, not on the interest component embedded in the award. The distinction between compensation and post-receipt interest was recognised, but the award-stage interest was held not to be revenue income.
Conclusion: The interest component in the MACT award is part of compensation, is a capital receipt, and is not taxable as income; the issue is answered in favour of the assessee.
Ratio Decidendi: Interest awarded as part of a compensation award for loss or injury under the Motor Vehicles Act assumes the character of compensation itself and is not taxable income until separately earned after receipt.