2002 (8) TMI 105

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....instance of the Department. These references pertain to the assessment years 1979-80, 1981-82 to 1985-86. The questions of law required to be answered are as follows: "1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the contention of the assessee that the rediscounting interest paid on bills did not accrue or arise to the assessee-bank by reas....

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....lding that the transactions contemplated between the assessee and the RBI/IDBI in refinancing scheme framed by the RBI/IDBI is an integrated transaction and cannot be considered as two separate transactions?" The assessee is a nationalised bank. The Assessing Officer while determining chargeable interest under the Interest-tax Act, 1974, made additions of rediscounting charges paid to the RBI and....

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....eme had held that: "The scheme, viewed as a whole, makes it clear that the assessee-bank is only a medium or a conduit pipe for the disbursement of the development fund for the implementation of the scheme for which it can retain up to 1.75 per cent. which alone accrues to the bank and in respect of the remaining interest received from the purchaser on the advances made to him, there is an overri....