Locus and delay defeat challenge to tax deduction on MACT award interest, without any ruling on validity.

A challenge to tax deduction at source on interest payable under Motor Accident Claims Tribunal awards was not entertained because the petitioner lacked personal locus to assail the statutory provision through a public interest litigation. The Court noted that such a validity challenge should ordinarily be brought by a person personally affected by the award or deduction, and it declined to examine the merits of the provision. The connected writ petition was also dismissed on delay and locus grounds, with procedural liberty left open for a properly maintainable petition.

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Outcome: The petition challenging the validity of Section 194A(3)(ixa) of the Income-tax Act, 1961 was dismissed, with no opinion expressed on the question of law raised.

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