Loan Processing Fees Examined as Interest Under Income Tax Act Sections 2(28A) and 194A; TDS Non-Compliance Triggers Section 40(a)(ia) Consequences.

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....Loan Processing fees - whether considered as interest for purpose of Section 2(28A) and 194A - assessee was obliged to deduct tax at source which it had not done so. Rigours of Section 40(a)(ia) is attracted - AT....