Where the assessee-bank received subsidy from the Reserve Bank of India under the Export Credit (Interest Subsidy) Scheme, 1968, the High Court held that since the assessee had not advanced any loan or given any advance to the RBI and the amount received represented subsidy or compensation for loss of interest, the same could not be treated as “interest” as defined under section 2(7) and, consequently, was not chargeable to tax under section 4 of the Interest-tax Act. (AY. 1992-93).
Bank of India v. DCIT [2025] 175 taxmann.com 905 (Bom) (HC)
Interest-tax Act, 1974
S. 2(7) : Interest-Subsidy received from RBI-Export Credit-Subsidy Scheme-Not interest-Not chargeable to tax. [S. 4, 260A, Reserve Bank of India Act, 1934(2 of 1934) S.42(IB)]
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