Allowing the petition the Court held that the interest awarded by the Motor Accident Claim Tribunal under section 171 of the Motor Vehicles Act, 1988, is not taxable under the Income-tax Act, 1961. The interest awarded in motor accident claim cases from the date of the claim petition till the passing of the award, or in the case of an appeal, till the judgment of the High Court in such appeal, would not be exigible to tax, not being an income. This position would not change on account of clause (b) of section 145A of the Act as it stood at the relevant time amended by Finance Act, 2009, which provision now finds place in sub-section (1) of section 145B of the Act. Neither clause (b) of section 145A, as it stood at the relevant time, nor clause (viii) of sub-section (2) of section 56 of the Act make the interest chargeable to tax, whether or not such interest is income of the recipient. Section 194A of the Act is only a provision for deduction of tax at source. Any provision for deduction of tax at source in the section would not govern the taxability of the receipt. The question of deduction of tax at source would arise only if the payment is in the nature of income of the payee. Insurance companies or the owners of motor vehicles depositing the requisite amount in due compliance with the awards of the Motor Accident Claims Tribunals shall deposit the full amount with the Tribunal and shall not deduct tax under section 194A of the Act on the interest awarded by the Motor Accident Claims Tribunal.