Discounting charges on bills of exchange are not interest

Delhi High Court in the case of DCIT Vs. Cargill Global Trading (I) (P) Limited on the issue of whether discounting charges paid to a non-resident on discounting of bills of exchange (BEs) can be characterized as ‘interest’, liable for withholding held that the discounting charges are not in the nature of ‘interest’ since they are not payable in respect of money borrowed or debt incurred by the Taxpayer. Accordingly, the discounting charges are business income, not covered by the special source rule applicable to interest income. As the recipient non-resident does not ...