S. 194A : Deduction at source-Interest other than interest on securities-Excess interest retained by nonbanking financial companies-loans purchased by bank-Upfront payment and allowing the originating NBFCs to retain part interest on such loan paid by the borrowers-No obligation to deduct tax at source-NBFCs have already offered to tax in their returns of income the interest earned on loans sold to the assessee-Levy of tax under section 201 (1) and levy of interest u/s 201(IA ) for failure to deduct u/s 194A, 194H or 194J is not applicable. [S.2(28A 194A, 194H, 194J 201(1), 201(IA)]