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The statutory notification exempting interest payments to corporations established under Central, State or Provincial Acts applies to the National Highways Authority of India as a Central Act corporation. CBDT Circular No. 18/2017, which concerns entities with unconditionally exempt income, cannot add conditions to or narrow that statutory notification. Accordingly, interest paid on mobilisation advances to the Authority is not subject to tax deduction at source, and the payer cannot be treated as an assessee-in-default or charged consequential interest.
The statutory notification exempting interest payments to corporations established under Central, State or Provincial Acts applies to the National Highways Authority of India as a Central Act corporation. CBDT Circular No. 18/2017, which concerns entities with unconditionally exempt income, cannot add conditions to or narrow that statutory notification. Accordingly, interest paid on mobilisation advances to the Authority is not subject to tax deduction at source, and the payer cannot be treated as an assessee-in-default or charged consequential interest.
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