Interest paid on money advanced by PSU from funds sanctioned by govt. not exempt from TDS u/s 196(i)

Brief of the case: The Hon’ble Punjab & Haryana High Court in the case of M/s Council for Citrus and Agri Juicing in Punjab Vs. CIT(TDS) held that the money lent by the public sector undertaking from the corpus fund created out of govt. sanctioned funds could not be deemed as loans advanced by the govt. and consequently, the interest payable on the same even if accruing to govt, could not be relieved from tax deduction u/s 196(i). Further, benefit of non-deduction of TDS u/s 196(i) is allowable only in case of interest or dividend payable to govt. in respect of securities or shares ...