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2007 (2) TMI 155

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....inst the order of the Income-tax Appellate Tribunal in ITA Nos.70 to 74/Mds/2002 28.2.2006, raising the following common substantial question of law. "Whether in the facts and circumstances of the case, the Tribunal was right in excluding additional discount charges from the chargeable interest under the Interest Tax Act?" 2. The assessee, a non-banking finance company, excluded additional disc....

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....ll is wholly distinct from loans and advances and the interest on the loans and advances alone is taxable under the Interest Tax Act and the character of an overdue bill is not synonymous with loans and advances and therefore, the interest on overdue bills is to be excluded from chargeable interest under the Interest Tax Act. 5. Applying the above ratio to the facts of the case, we hold that the....