2006 (9) TMI 561

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....ved by an order dated 24-2-2006 passed by the Income-tax Appellate Tribunal, Delhi Bench "B" in ITA Nos. 38, 39/Del./01 and 19/Del./2002 relevant for the assessment years 1996-97, 1997-98 and 1998-99. 2. The controversy in this case is whether the assessee is liable to pay interest-tax under the Interest-tax Act, 1974 on the amount earned by it in respect of the transactions relating to hire-pu....

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....terest.-Subject to the provisions of this Act, the chargeable interest of any previous year of a credit institution shall be the total amount of interest (other than interest on loans and advances made to other credit institutions or to any co-operative society engaged in carrying on the business of banking, accruing or arising to the credit institution in that previous year." [Emphasis supplied] ....

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....ord, it is quite clear that assessee does not give any loan or advance to its customers and has not earned any interest on any such alleged loan or advance. The vehicles are directly purchased by the assessee in its own name from the manufacturer and the customer is not a party to that transaction. It is only thereafter that the assessee, under an agreement hires out the vehicle to the customer fo....