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    <title>2025 (6) TMI 1490 - BOMBAY HIGH COURT</title>
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    <description>Subsidy received by a bank from the Reserve Bank of India under the Export Credit (Interest Subsidy) Scheme, 1968 was held not to be &quot;interest&quot; within the meaning of section 2(7) of the Interest Tax Act, 1974. Applying strict construction of fiscal legislation, the Court held that tax liability must arise from clear words of the charging provision and that the definition of interest is confined to amounts arising from loans and advances in India, subject only to the stated inclusions and exclusions. As the subsidy was compensation for loss on interest and not consideration on a loan or advance, it was not chargeable to interest tax.</description>
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