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2015 (7) TMI 360 - AT - Income TaxShort deduction on account of interest - @194I or section 194C - CIT(A) deleted disallowance - Held that:- Having regard to the agreement entered into by the assessee, the contents of which have been summarized by ld. CIT(A) in his order, it is evident that assessee had not acquired any right of possession of the buses i.e. vehicles, which is an essential ingredient of hiring. The assessee had no interest i.e. as a lessee or sub-lessee or tenant in respect of the buses which were being used for transportation of the employees. The existence of landlord/ tenant relation or licensor/licensee is a must before the payment in question can be termed as a rent. Accordingly, we see no reason to interfere in the order of ld. CIT(A) in deleting the addition on account short deduction as also the interest charged u/s 201(1)/201(1A). - Decided against revenue.
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