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2015 (11) TMI 409 - HC - Income TaxNon deduction of TDS u/s 194A - Loan amount raised from the State Government and the interest payable to the Government - whether the issue is covered under Section 196(i) of the Act? - Held that:- The assessee was unable to show from the perusal of Annexures A-4 and A-5 appended along with the appeal that the payment of interest was made to the Government except to repeat that the corpus fund was created by the Government from which the loan was advanced to the appellant. A perusal of Annexure A-4 shows that it is a certificate issued by the PAIC that the corpus fund belong to the State Government of Punjab and an income arising out of it belonged to the Government of Punjab. Annexure A-4 is a self-serving certificate issued without any corroboration from any supporting material. Annexure A-5 also does not advance the case of the appellant as it is the minutes of meeting of Corpus Fund Committee only. Thus, it cannot be said that the interest paid by the appellant was to the Government and would fall under Section 196(i) of the Act. - Decided against assessee.
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