The assessee was awarded compensation in a motor accident claim, and the paying insurance company deducted TDS on the interest component under Section 194A. Relying on its earlier judgment in Rupesh Rashmikant Shah v. UOI, the High Court held that interest awarded on compensation from the date of the claim petition until the date of the award or the judgment in appeal does not constitute ‘income’ and is therefore not exigible to tax. The Court observed that Section 194A is only a provision for deduction of tax at source and cannot govern the taxability of a receipt. Accordingly, the insurance company was directed to refund the TDS amount that was deducted on the interest which had accrued up to the date of the High Court’s judgment.