https://www.taxtmi.com/caselaws?id=794910 A non-recourse sale or assignment of future rental receivables does not create borrowing or debt between the assessee and financiers where the financiers have recourse only against the renters and the assessee has no repayment obligation. Under Section 2(28A), interest requires an amount payable in respect of money borrowed or debt incurred; Sections 194A, 201(1), and 201(1A) operate on that legal characterisation. The difference between aggregate future rentals and the upfront consideration is treated as sale consideration reflecting valuation and the time value of money, rather than interest or discounting charges. Financiers' accounting treatment does not determine the transaction's legal character, and tax deduction at source under Section 194A is therefore not attracted. en-us Mon, 06 Jul 2026 00:00:00 +0530 Tue, 14 Jul 2026 08:26:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794910 A non-recourse sale or assignment of future rental receivables does not create borrowing or debt between the assessee and financiers where the financiers have recourse only against the renters and the assessee has no repayment obligation. Under Section 2(28A), interest requires an amount payable in respect of money borrowed or debt incurred; Sections 194A, 201(1), and 201(1A) operate on that legal characterisation. The difference between aggregate future rentals and the upfront consideration is treated as sale consideration reflecting valuation and the time value of money, rather than interest or discounting charges. Financiers' accounting treatment does not determine the transaction's legal character, and tax deduction at source under Section 194A is therefore not attracted. Case-Laws Income Tax Mon, 06 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794910