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Appellate Tribunal held that when interest income was credited to PEL's account by original borrowers, TDS obligations u/ss 193/194A were already fulfilled. The appellant, who later acquired PEL's lending rights, was not required to deduct TDS again on the same interest payments. No lender-borrower relationship existed between appellant and PEL, making appellant not a "person responsible" for TDS under the Act. Payments exceeding principal value of ICDs/NCDs/Term Loans cannot be classified as 'interest' u/s 2(28A)/2(28B). ITAT deleted demand raised u/s 201(1)/201(1A), noting that income characterization can differ between recipient and payer. Appeal allowed.
Appellate Tribunal held that when interest income was credited to PEL's account by original borrowers, TDS obligations u/ss 193/194A were already fulfilled. The appellant, who later acquired PEL's lending rights, was not required to deduct TDS again on the same interest payments. No lender-borrower relationship existed between appellant and PEL, making appellant not a "person responsible" for TDS under the Act. Payments exceeding principal value of ICDs/NCDs/Term Loans cannot be classified as 'interest' u/s 2(28A)/2(28B). ITAT deleted demand raised u/s 201(1)/201(1A), noting that income characterization can differ between recipient and payer. Appeal allowed.
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