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    <title>1999 (10) TMI 87 - ITAT ALLAHABAD-A</title>
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    <description>A Residuary Non-Banking Company was held outside the definition of a miscellaneous finance company for the relevant year because the then-existing Interest Tax Act did not expressly include it; the later insertion of a specific clause confirmed that it had not previously been covered. Interest earned on investments in securities and debentures was also treated as outside chargeable interest, because the statutory definition of &quot;interest&quot; was confined to loans and advances and enumerated inclusions, while investments made under regulatory directions remained distinct from lending. The construction favourable to the taxpayer was adopted where the taxing definition was ambiguous.</description>
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