https://www.taxtmi.com/highlights?id=77806 The case involves TDS issues u/s 194A, 194H, and 194J concerning surplus interest retained by NBFCs. The assessee, a bank, purchased loans from NBFCs with a tripartite agreement allowing NBFCs to retain part interest. The tribunal held that the retained interest does not qualify as "interest" u/s 194A as the assessee did not borrow funds from NBFCs. Similarly, no TDS is required u/s 194H as NBFCs did not act on behalf of the assessee. Regarding u/s 194J, the consideration for loan assignment includes upfront payment and lower interest, not subject to TDS. Tax u/s 201(1) and interest u/s 201(1A) are not applicable as NBFCs already paid tax on interest earned. Decision favors the assessee. en-us Sat, 25 May 2024 08:31:44 +0530 Sat, 25 May 2024 08:31:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=77806 The case involves TDS issues u/s 194A, 194H, and 194J concerning surplus interest retained by NBFCs. The assessee, a bank, purchased loans from NBFCs with a tripartite agreement allowing NBFCs to retain part interest. The tribunal held that the retained interest does not qualify as "interest" u/s 194A as the assessee did not borrow funds from NBFCs. Similarly, no TDS is required u/s 194H as NBFCs did not act on behalf of the assessee. Regarding u/s 194J, the consideration for loan assignment includes upfront payment and lower interest, not subject to TDS. Tax u/s 201(1) and interest u/s 201(1A) are not applicable as NBFCs already paid tax on interest earned. Decision favors the assessee. Highlights Income Tax Sat, 25 May 2024 08:31:44 +0530 https://www.taxtmi.com/highlights?id=77806