S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Interest-Interest on loans paid to Indian and Foreign banks-Legal fees-Not liable to deduct tax at source-Disallowance is not justified-DTAA-India-USA-Rebate for early payment is not interest-Not liable to deduct tax at source.[S.2(28A), 194A, 195, Art. 12]