TMI Blog2006 (9) TMI 561X X X X Extracts X X X X X X X X Extracts X X X X ..... Delhi Bench B in ITA Nos. 38, 39/Del./01 and 19/Del./2002 relevant for the assessment years 1996-97, 1997-98 and 1998-99. 2. The controversy in this case is whether the assessee is liable to pay interest-tax under the Interest-tax Act, 1974 on the amount earned by it in respect of the transactions relating to hire-purchase of vehicles. 3. It appears that the assessee purchased vehicles fr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vious year of a credit institution shall be the total amount of interest (other than interest on loans and advances made to other credit institutions or to any co-operative society engaged in carrying on the business of banking, accruing or arising to the credit institution in that previous year. [Emphasis supplied] 5. Chargeable interest is defined in section 2(5) to mean the total amount ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed any interest on any such alleged loan or advance. The vehicles are directly purchased by the assessee in its own name from the manufacturer and the customer is not a party to that transaction. It is only thereafter that the assessee, under an agreement hires out the vehicle to the customer for a charge under a hire-purchase agreement. The finding of the Commissioner of Income-tax (Appeals) as w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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