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    <title>2018 (6) TMI 453 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>Payment described as 12% per annum in a land acquisition award was treated as additional compensation under section 23(1A) of the Land Acquisition Act, 1894, not as interest. The substance of the payment, rather than its label in the award, governed its tax character. Because the amount was additional compensation and not interest, no tax deduction at source was required under section 194A of the Income-tax Act, 1961. The competent authority&#039;s clarification supported the Tribunal&#039;s view, and the Revenue&#039;s challenge failed.</description>
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      <description>Payment described as 12% per annum in a land acquisition award was treated as additional compensation under section 23(1A) of the Land Acquisition Act, 1894, not as interest. The substance of the payment, rather than its label in the award, governed its tax character. Because the amount was additional compensation and not interest, no tax deduction at source was required under section 194A of the Income-tax Act, 1961. The competent authority&#039;s clarification supported the Tribunal&#039;s view, and the Revenue&#039;s challenge failed.</description>
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