Supreme Court of India

M/s. State Bank of Patiala through General Manager v. Commissioner of Income Tax, Patiala

Neutral citation
Reported as [2015] 12 S.C.R. 243
Bench A. K. Sikri and Rohinton Fali Nariman JJ.
Decided 18 November 2015

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

1 Supreme Court bench has cited this judgment.

What the Court ordered

We hold that the amount recovered by the G assessee from the constituents (borrower) cannot be taxed as interest in the hands of the assessee.

Judgment, page 19

From the headnote

Interest Tax Act, 1974: c s.2(7) - Interest payable on default in payment of amounts due under the discounted bill of exchange - Liability to pay tax on such interest under the Act of 1974- Held: Tax not payable - Interest is chargeable to tax under the Interest Tax Act only if it arises directly from a loan or advance - This is clear from the use of the word "on" ins. 2(7) of the Act - Interest payable "on" a discounted bill of exchange cannot therefore be equated with interest payable "on" a loan or advance. s.2(7)- Guarantee fees paid to the Deposit Insurance and Credit Guarantee

Authorities it was built on

Where later benches applied it

Of those, 1 relied on

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