Allowing the appeal of the revenue the Tribunal held that , usance charges paid by the respondent to its holding company for delayed payment of goods was not part of purchase price of goods but same was interest within meaning of S 2(28A) of the Act. CIT v. Vijay Ship Breaking Corpn. (2003) 261 ITR 113 (Guj.)(HC) ( AY. 2003-04)
ACIT v. Overseas Trading and Shipping Co. (P.) Ltd. (2018) 173 ITD 446 (Rajkot)(Trib.)
S. 2(28A) : Interest -Usance interest -Paid to holding company for delayed payment for purchase of goods was not part of purchase price, but interest–Liable to deduct tax at source-DTAA-India –Singapore, [S. 40(a)(i), 195, Art.7, 11]