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Interest included in a foreign arbitral award, once the award is enforced as a court decree, assumes the character of a judgment debt rather than "interest" under the Income-tax Act. The interest component, although labelled as interest in the award, was treated as part of the decretal damages and therefore outside the scope of taxable interest income in India. The related tax addition was deleted and the appeal succeeded.
Interest included in a foreign arbitral award, once the award is enforced as a court decree, assumes the character of a judgment debt rather than "interest" under the Income-tax Act. The interest component, although labelled as interest in the award, was treated as part of the decretal damages and therefore outside the scope of taxable interest income in India. The related tax addition was deleted and the appeal succeeded.
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