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    <title>2016 (7) TMI 1047 - DELHI HIGH COURT</title>
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    <description>Interest earned on surplus funds placed as deposits with SAIL was analysed under section 2(7) of the Interest Tax Act, 1974, which was treated as an exhaustive definition covering only interest on loans and advances together with specified inclusions and exclusions. The distinction between a loan and a deposit was treated as material: loans are advanced on terms fixed by the lender, while deposits are made to earn a return on investment. Applying the Special Bench view that deposits are not loans, the interest on such deposits was held outside section 2(7) and therefore not chargeable to interest tax. Consistency with the Revenue&#039;s acceptance of that view for earlier years was also noted.</description>
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      <title>2016 (7) TMI 1047 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=330449</link>
      <description>Interest earned on surplus funds placed as deposits with SAIL was analysed under section 2(7) of the Interest Tax Act, 1974, which was treated as an exhaustive definition covering only interest on loans and advances together with specified inclusions and exclusions. The distinction between a loan and a deposit was treated as material: loans are advanced on terms fixed by the lender, while deposits are made to earn a return on investment. Applying the Special Bench view that deposits are not loans, the interest on such deposits was held outside section 2(7) and therefore not chargeable to interest tax. Consistency with the Revenue&#039;s acceptance of that view for earlier years was also noted.</description>
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