New India Assurance Co. Ltd. v. CIT (2024) 460 ITR 624 (Pat)(HC)

S. 194A : Deduction at source-Interest other than interest on securities-Interest on compensation awarded by Motor Accidents Claims Tribunal is wholly exempt-Amendment of section 194A(3) (ix), Art.226, Motor Accident Claims Tribunal.]

Allowing the petition the Court  held that sub-clause (ix) of sub-section (3) of section 194A, speaks of such exemption from deduction of tax, from the interest income, when the aggregate amount of such income credited or paid during the financial year exceeds Rs. 50,000. Section 194A(3)(ix) has been substituted with effect from June 1, 2015 providing for exemption in respect of “income credited by way of interest on the compensation amount awarded by the Motor Accidents Claims Tribunal”. On the provision coming into force from June 1, 2015, no tax can be deducted even on the interest component.  Court also observed that the Tribunals has to follow proper procedure for refund, if the claimant does not have income in excess of the taxable limit under the Income-tax Act.