Assessee purchased loans (including NCDs, ICDs and term loans) from Piramal Enterprises Ltd and  Piramal Capital Ltd  at carrying value, comprising principal and accrued interest till the date of transfer of the loan. During the survey under section 133B(2), it was found that assessee typically accrued interest in books based on the period of its holding of the loan and had defaulted in deducting TDS on accrued interest and excess interest on revision in interest rates. Accordingly, the Assessing Officer treated the assessee as an ‘assessee-in-default’ for non-deduction of tax under section 194A on payment of consideration with respect to accrued interest for acquiring loans from ‘P’ and ‘C’ and raised a demand. CIT(A) allowed the appeal. On appeal, the Tribunal held that payment made by assessee to transferors towards the purchase of loans was purchase consideration for acquiring the right to receive principal along with interest from the debtor at maturity and no part of the consideration could be termed as ‘interest’ paid by the assessee to transferors. Since no part of the consideration paid by the assessee could be termed as ‘interest’ paid by the assessee to transferors, there was no obligation to deduct tax at source under section 194A. (AY. 2019-20)