https://www.taxtmi.com/highlights?id=101681 Non-recourse assignment of future rent receivables to financiers constitutes a sale of receivables rather than borrowing where the financier can proceed only against the renter and the assignor bears no repayment obligation. The difference between aggregate future rentals and the consideration received is therefore negotiated sale consideration, not interest under section 2(28A), and accounting treatment cannot alter that legal character. Since no borrowing or interest payment existed, section 194A did not apply; the assessee could not be treated as in default under section 201(1) or charged interest under section 201(1A). The related demands for the assessment years 2018-19 to 2024-25 were deleted. en-us Tue, 14 Jul 2026 08:26:27 +0530 Tue, 14 Jul 2026 08:26:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=101681 Non-recourse assignment of future rent receivables to financiers constitutes a sale of receivables rather than borrowing where the financier can proceed only against the renter and the assignor bears no repayment obligation. The difference between aggregate future rentals and the consideration received is therefore negotiated sale consideration, not interest under section 2(28A), and accounting treatment cannot alter that legal character. Since no borrowing or interest payment existed, section 194A did not apply; the assessee could not be treated as in default under section 201(1) or charged interest under section 201(1A). The related demands for the assessment years 2018-19 to 2024-25 were deleted. Highlights Income Tax Tue, 14 Jul 2026 08:26:27 +0530 https://www.taxtmi.com/highlights?id=101681