In the result, this appeal of the Revenue is dismissed
Bench: Shri Sandeep Gosain & Shri Manoj Kumar Aggarwala.C.I.T. Vs. Smt. Alpana Gupta, 4-A-15, Central Circle, Jawahar Nagar, Bikaner. Sriganganagar. Pan No. Aiepg 8893 R
239 Taxman 530 (Del.) (HC), the Hon’ble Delhi High Court has held that the discounting charges is not covered by the definition of interest u/s 2(28A) and the assessee is not payer of the discounting charges, hence, section 194A is not applicable. Similarly, the Coordinate Bench of the Ahmadabad Tribunal in the case of Omkara Impex and Merchandise