Our restaurant and banquet bills carry a tip that the customer adds on the card. The money lands in our bank account and we hand it to the staff with their wages. The department says that is salary we should have deducted on. Is it?
No. The Supreme Court held that a tip is not salary at all, and that the route it travels — cash into the waiter's hand or a card entry through the employer's bank account — makes no difference. Section 15(b) taxes what is paid or allowed by or on behalf of an employer, and the word employer presupposes a contract of employment; the employee has no vested right to claim a tip from his employer, and the amount has no reference to his contract of employment. The employer receives the money in a fiduciary capacity as trustee and is only a conduit between customer and staff. The tip is the employee's income from other sources under section 56(1). Section 192 is therefore not attracted, the employer is not an assessee in default, and no interest under section 201(1A) arises.
Decided by the Supreme Court (Supreme Court of India - Kurian Joseph and R.F. Nariman, JJ., Civil Appeals Nos. 4435-4444 of 2016) on 2016-04-26, reported as AIR 2016 SC 2127; Civil Appeals Nos. 4435-4444 of 2016. It bears on section 192, section 192(3), section 15, section 17, section 17(3)(ii), section 201, section 201(1), section 201(1A), section 56(1), section 271C, section 392 (Act of 2025), section 398 (Act of 2025) of the Income Tax Act 1961, in TDS Defaults and Salary & Perquisites matters.
Every hotel, restaurant and banqueting business in the country pools a tip and pays it out with the wages, and a TDS survey finds it in an afternoon. Before this judgment the argument ran on the plumbing — cash in the hand was safe, the card entry was not, because the money had touched the employer's bank account. The Supreme Court moved the question off the plumbing altogether. What matters is whether the employee can claim the amount from the employer as of right under his contract of employment. If he cannot, the employer is a trustee handing over somebody else's money, and section 192 never engages, so there is no default and no interest. That reasoning is not confined to hotels: it reaches any pass-through where an outsider's money is routed to staff through the payroll, and it is the reason the department's habit of treating everything that leaves the employer's account as salary does not hold.
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The assessees were in the business of owning, operating and managing hotels. Surveys showed that they had been paying tips over to their employees without deducting tax. The Assessing Officer treated the receipt of the tips as income under the head salaries, held the assessees liable to deduct under section 192, treated them as assessees in default under section 201(1) and charged interest under section 201(1A); the assessment order in the lead matter is dated 29 March 2007 and the years are assessment years 2003-04, 2004-05 and 2005-06. The Commissioner (Appeals) allowed the assessees' appeals, holding that they could not be treated as assessees in default, and the Tribunal dismissed the Revenue's appeals. By a common judgment dated 11 May 2011 the Delhi High Court reversed that in part. It framed two questions — whether the Tribunal had erred in holding the assessee was not an assessee in default for short or non-deduction on banquet and restaurant tips, and whether it had erred in holding those tips were not profits in lieu of salary within section 17(3)(ii). It then drew a line by the route the money took. Where a tip is received by the employee directly in cash, it said, the employer has no role to play. But the moment a tip is included and paid by credit card, the amount goes into the employer's account and is then distributed, and receipt of that money from the employer amounts to salary within the extended definition in section 17. Both sides appealed. Penalty under section 271C had been separately initiated, and by an order dated 19 June 2013 penalty had been levied on ITC in one of the connected matters.
The appeals filed by the assessees were allowed and the Revenue's connected civil appeals were dismissed: "The appeals filed by the assessees are, therefore, allowed and civil appeals arising out of SLP (Civil) Nos.9587-9589 of 2012 filed by Revenue are dismissed. The judgment of the High Court is set aside with no order as to costs." Tips do not fall within section 15(b) at all, because there is no vested right in the employee to claim any amount of tip from his employer and the amount has no reference to the contract of employment; the employer receives tips in a fiduciary capacity as trustee and is only a conduit between the customer and the employee. Income from tips is chargeable in the hands of the employees as income from other sources, so section 192 is not attracted on these facts. Because the appellants are outside section 192 they cannot be stated to be assessees in default, and no question of interest under section 201(1A) arises. Since the High Court judgment was set aside in toto, none of its observations on penalty bind either party.
The Court began with the charge rather than with the machinery. Section 15(a) makes salary taxable on accrual — it refers to salary due from an employer or a former employer, whether paid or not. Section 15(b) covers salary paid or allowed to an employee in the previous year by or on behalf of an employer. The Court held that even assuming "allowed" is an expression of width, it requires a vested right in the employee, and on these facts there is none: a tip is a purely voluntary amount that a customer may or may not pay. It then pressed on the word employer. An employer is a person who employs another under a contract of employment, express or implied, to perform work for the employer. Section 15(b) therefore has reference to that contract, and salary paid or allowed must have reference to it. The amount of a tip paid by the employer to the employee has no such reference. Tips are received by the employer in a fiduciary capacity as trustee for payments received from customers, which are then disbursed to the employees for service rendered to the customer. The Revenue's answer — that there is an indirect reference, because but for the contract of employment no tips could have been paid at all — was rejected: on that argument even cash tips, which the Revenue and the High Court both accepted were outside section 192, would be caught. The same reading was carried into section 17(3). The Court pointed out that the sub-section itself uses two different expressions, "employer" in sub-clause (ii) and "person" in sub-clause (iii), and that "person" is the wider of the two. A payment that is to be profits in lieu of salary under sub-clause (ii) must therefore come from the employment relationship itself. On where the amount does belong, the Court followed Emil Webber: a payment made by someone who is not the assessee's employer cannot be brought within section 17, and must be placed under section 56(1) as income from other sources. Karamchari Union was held not to support the Revenue; there the Court had been asked whether city compensatory allowance and house rent allowance paid by an employer fell within section 17, and it does not follow that any amount received from an employer is profit in lieu of salary. The English authorities on tips, Calvert v Wainwright and Moorhouse v Dooland, were read against Schedule E, which does not require the employer nexus the Indian provisions require; from Wrottesley v Regent Street Florida Restaurant the Court took the proposition that even if the tips box were in the employer's actual custody he would have no title to the money, holding it in a fiduciary capacity for his employees. The Court then took its concluding test from an authority the assessees had cited. In Hochstrasser v Mayes the House of Lords, construing paragraph 2 of Schedule E, held that it is not enough for the Crown to establish that the employee would not have received the sum had he not been an employee at all; the service agreement must be the causa causans and not merely the causa sine qua non. Paragraph 2 of that Schedule, unlike paragraph 1, comes close to section 15 as the Court had construed it, so that test applied. On it, the contract of employment was not the proximate cause for the receipt of tips by the employee from a customer, and the amounts fell outside the dragnet of sections 15 and 17. The machinery point was argued both ways — that section 192 cannot be complied with because an employer cannot predicate how much each employee will get by way of tips, and against that, that section 192(3) allows monthly estimates and adjustment. The Court did not need to resolve it. Having held the appellants outside section 192, it applied Eli Lilly, at paragraph 91, for the proposition that interest under section 201(1A) can only be levied when a person is declared an assessee in default, and held that no question of interest arose.
Tips are received by the employer in a fiduciary capacity as trustee for payments that are received from customers which they disburse to their employees for service rendered to the customer.
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Handle my notice → Ask a CA on WhatsAppNo. The Supreme Court held that a tip is not salary at all, and that the route it travels — cash into the waiter's hand or a card entry through the employer's bank account — makes no difference. Section 15(b) taxes what is paid or allowed by or on behalf of an employer, and the word employer presupposes a contract of employment; the employee has no vested right to claim a tip from his employer, and the amount has no reference to his contract of employment. The employer receives the money in a fiduciary capacity as trustee and is only a conduit between customer and staff. The tip is the employee's income from other sources under section 56(1). Section 192 is therefore not attracted, the employer is not an assessee in default, and no interest under section 201(1A) arises. This was decided by the Supreme Court (Supreme Court of India - Kurian Joseph and R.F. Nariman, JJ., Civil Appeals Nos. 4435-4444 of 2016) and bears on section 192, section 192(3), section 15, section 17, section 17(3)(ii), section 201, section 201(1), section 201(1A), section 56(1), section 271C, section 392 (Act of 2025), section 398 (Act of 2025) of the Income Tax Act 1961. It is reported as AIR 2016 SC 2127; Civil Appeals Nos. 4435-4444 of 2016. Every hotel, restaurant and banqueting business in the country pools a tip and pays it out with the wages, and a TDS survey finds it in an afternoon. Before this judgment the argument ran on the plumbing — cash in the hand was safe, the card entry was not, because the money had touched the employer's bank account. The Supreme Court moved the question off the plumbing altogether. What matters is whether the employee can claim the amount from the employer as of right under his contract of employment. If he cannot, the employer is a trustee handing over somebody else's money, and section 192 never engages, so there is no default and no interest. That reasoning is not confined to hotels: it reaches any pass-through where an outsider's money is routed to staff through the payroll, and it is the reason the department's habit of treating everything that leaves the employer's account as salary does not hold. If it applies to you, the first step is this: Separate money that is yours from money that merely passes through you. A service charge you levy on the bill is your own receipt, and what you then pay staff out of it is their salary. A tip the customer chooses to add is not your receipt, and the card rail does not convert it into one.
The assessees were in the business of owning, operating and managing hotels. Surveys showed that they had been paying tips over to their employees without deducting tax. The Assessing Officer treated the receipt of the tips as income under the head salaries, held the assessees liable to deduct under section 192, treated them as assessees in default under section 201(1) and charged interest under section 201(1A); the assessment order in the lead matter is dated 29 March 2007 and the years are assessment years 2003-04, 2004-05 and 2005-06. The Commissioner (Appeals) allowed the assessees' appeals, holding that they could not be treated as assessees in default, and the Tribunal dismissed the Revenue's appeals. By a common judgment dated 11 May 2011 the Delhi High Court reversed that in part. It framed two questions — whether the Tribunal had erred in holding the assessee was not an assessee in default for short or non-deduction on banquet and restaurant tips, and whether it had erred in holding those tips were not profits in lieu of salary within section 17(3)(ii). It then drew a line by the route the money took. Where a tip is received by the employee directly in cash, it said, the employer has no role to play. But the moment a tip is included and paid by credit card, the amount goes into the employer's account and is then distributed, and receipt of that money from the employer amounts to salary within the extended definition in section 17. Both sides appealed. Penalty under section 271C had been separately initiated, and by an order dated 19 June 2013 penalty had been levied on ITC in one of the connected matters. The matter was decided on 2016-04-26 by the Supreme Court (Supreme Court of India - Kurian Joseph and R.F. Nariman, JJ., Civil Appeals Nos. 4435-4444 of 2016). On those facts the Supreme Court held as follows. The appeals filed by the assessees were allowed and the Revenue's connected civil appeals were dismissed: "The appeals filed by the assessees are, therefore, allowed and civil appeals arising out of SLP (Civil) Nos.9587-9589 of 2012 filed by Revenue are dismissed. The judgment of the High Court is set aside with no order as to costs." Tips do not fall within section 15(b) at all, because there is no vested right in the employee to claim any amount of tip from his employer and the amount has no reference to the contract of employment; the employer receives tips in a fiduciary capacity as trustee and is only a conduit between the customer and the employee. Income from tips is chargeable in the hands of the employees as income from other sources, so section 192 is not attracted on these facts. Because the appellants are outside section 192 they cannot be stated to be assessees in default, and no question of interest under section 201(1A) arises. Since the High Court judgment was set aside in toto, none of its observations on penalty bind either party.
The Court began with the charge rather than with the machinery. Section 15(a) makes salary taxable on accrual — it refers to salary due from an employer or a former employer, whether paid or not. Section 15(b) covers salary paid or allowed to an employee in the previous year by or on behalf of an employer. The Court held that even assuming "allowed" is an expression of width, it requires a vested right in the employee, and on these facts there is none: a tip is a purely voluntary amount that a customer may or may not pay. It then pressed on the word employer. An employer is a person who employs another under a contract of employment, express or implied, to perform work for the employer. Section 15(b) therefore has reference to that contract, and salary paid or allowed must have reference to it. The amount of a tip paid by the employer to the employee has no such reference. Tips are received by the employer in a fiduciary capacity as trustee for payments received from customers, which are then disbursed to the employees for service rendered to the customer. The Revenue's answer — that there is an indirect reference, because but for the contract of employment no tips could have been paid at all — was rejected: on that argument even cash tips, which the Revenue and the High Court both accepted were outside section 192, would be caught. The same reading was carried into section 17(3). The Court pointed out that the sub-section itself uses two different expressions, "employer" in sub-clause (ii) and "person" in sub-clause (iii), and that "person" is the wider of the two. A payment that is to be profits in lieu of salary under sub-clause (ii) must therefore come from the employment relationship itself. On where the amount does belong, the Court followed Emil Webber: a payment made by someone who is not the assessee's employer cannot be brought within section 17, and must be placed under section 56(1) as income from other sources. Karamchari Union was held not to support the Revenue; there the Court had been asked whether city compensatory allowance and house rent allowance paid by an employer fell within section 17, and it does not follow that any amount received from an employer is profit in lieu of salary. The English authorities on tips, Calvert v Wainwright and Moorhouse v Dooland, were read against Schedule E, which does not require the employer nexus the Indian provisions require; from Wrottesley v Regent Street Florida Restaurant the Court took the proposition that even if the tips box were in the employer's actual custody he would have no title to the money, holding it in a fiduciary capacity for his employees. The Court then took its concluding test from an authority the assessees had cited. In Hochstrasser v Mayes the House of Lords, construing paragraph 2 of Schedule E, held that it is not enough for the Crown to establish that the employee would not have received the sum had he not been an employee at all; the service agreement must be the causa causans and not merely the causa sine qua non. Paragraph 2 of that Schedule, unlike paragraph 1, comes close to section 15 as the Court had construed it, so that test applied. On it, the contract of employment was not the proximate cause for the receipt of tips by the employee from a customer, and the amounts fell outside the dragnet of sections 15 and 17. The machinery point was argued both ways — that section 192 cannot be complied with because an employer cannot predicate how much each employee will get by way of tips, and against that, that section 192(3) allows monthly estimates and adjustment. The Court did not need to resolve it. Having held the appellants outside section 192, it applied Eli Lilly, at paragraph 91, for the proposition that interest under section 201(1A) can only be levied when a person is declared an assessee in default, and held that no question of interest arose. In the words reproduced by the source cited on this page: "Tips are received by the employer in a fiduciary capacity as trustee for payments that are received from customers which they disburse to their employees for service rendered to the customer." The decision followed or applied Emil Webber v. Commissioner of Income Tax - followed, that a payment by someone who is not the employer falls under section 56(1) as income from other sources; Karamchari Union, Agra v. Union of India, (2000) 3 SCC 335 - distinguished; it decided only that city compensatory allowance and house rent allowance paid by an employer fall within section 17; Commissioner of Income Tax, New Delhi v. Eli Lilly and Company (India) Private Limited, (2009) 15 SCC 1 - applied at paragraph 91, that interest under section 201(1A) can only be levied when a person is declared an assessee in default; Wrottesley v. Regent Street Florida Restaurant - relied on, that the employer has no title to money in the tips box; Hochstrasser (Inspector of Taxes) v. Mayes, [1960] A.C. 376 - the proximity test taken from it and applied: the service agreement must be the causa causans and not merely the causa sine qua non of the receipt; Commissioner of Income-tax, Kerala v. L.W. Russel, 53 ITR 91 - applied, that an employee must have a vested right to receive an amount from his employer before it can be taxed as salary; Rambagh Palace Hotel - its statement that the true character of tips is not a payment made by the management but a transfer of what is collected from the customer and paid to the staff was held equally applicable; Calvert v. Wainwright and Moorhouse v. Dooland - considered and held to turn on Schedule E, which does not require the employer nexus the Indian provisions require; Commissioner of Income Tax v. ITC Ltd (Delhi High Court, judgment dated 11 May 2011) - the judgment under appeal, set aside in toto.
It was decided by the Supreme Court on 2016-04-26 and is reported as AIR 2016 SC 2127; Civil Appeals Nos. 4435-4444 of 2016. Binding on every court and authority in India. A Supreme Court decision binds every assessing officer, every Commissioner (Appeals), every bench of the Income Tax Appellate Tribunal and every High Court in India. An officer who declines to follow it is acting contrary to law, and that refusal is itself a ground of appeal. On section 192, section 192(3), section 15, section 17, section 17(3)(ii), section 201, section 201(1), section 201(1A), section 56(1), section 271C, section 392 (Act of 2025), section 398 (Act of 2025), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It helps the taxpayer. The appeals filed by the assessees were allowed and the Revenue's connected civil appeals were dismissed: "The appeals filed by the assessees are, therefore, allowed and civil appeals arising out of SLP (Civil) Nos.9587-9589 of 2012 filed by Revenue are dismissed. The judgment of the High Court is set aside with no order as to costs." Tips do not fall within section 15(b) at all, because there is no vested right in the employee to claim any amount of tip from his employer and the amount has no reference to the contract of employment; the employer receives tips in a fiduciary capacity as trustee and is only a conduit between the customer and the employee. Income from tips is chargeable in the hands of the employees as income from other sources, so section 192 is not attracted on these facts. Because the appellants are outside section 192 they cannot be stated to be assessees in default, and no question of interest under section 201(1A) arises. Since the High Court judgment was set aside in toto, none of its observations on penalty bind either party. It arises in TDS Defaults and Salary & Perquisites matters, on section 192, section 192(3), section 15, section 17, section 17(3)(ii), section 201, section 201(1), section 201(1A), section 56(1), section 271C, section 392 (Act of 2025), section 398 (Act of 2025) of the Income Tax Act 1961, and was decided by Supreme Court of India - Kurian Joseph and R.F. Nariman, JJ., Civil Appeals Nos. 4435-4444 of 2016. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Read your own employment terms before you rely on this. The Court's test is whether the employee can claim the amount from the employer as of right. If your appointment letters or a settlement guarantee each employee a share of the tip pool, you are outside this judgment and the amount may well be salary in your hands. Where a section 201(1) order and section 201(1A) interest are already on you for tips, attack the foundation rather than the quantum. The holding is that you are not a person responsible for paying salary under section 192 at all, so the default falls and the interest falls with it. Check separately what happened to penalty. Penalty under section 271C was initiated by separate proceedings here, and the Court set the High Court judgment aside in full and said none of its observations on penalty would bind either party. A penalty order resting on those observations needs its own challenge. Tell the staff where the amount belongs. The tip is their income from other sources under section 56(1) and goes into their return. This judgment relieves the hotel, not the waiter. For a credit or payment on or after 1 April 2026, the salary deduction provision is section 392 of the Income-tax Act, 2025 and section 398 stands in place of section 201. What this judgment settles is what salary is, and that question travels with the head.
Still good law. Nothing later was found that overrules, doubts or narrows this decision, and no citator service was consulted. Three limits on how far the holding travels are worth fixing before relying on it. The first is that it turns on the absence of a vested right. The Court's words are that there is no vested right in the employee to claim any amount of tip from his employer, and that the payment has no reference to the contract of employment. Where the terms of employment or a settlement give staff an enforceable share of a pooled amount, the foundation of the holding is gone and the amount can be salary. The second is the test the Court finally applied. Taking the proximity test from Hochstrasser v Mayes, it held that the contract of employment was not the proximate cause for the receipt of tips by the employee from a customer, so the amounts fell outside sections 15 and 17. An arrangement in which the employment is the proximate cause, and not merely the reason the employee was in a position to be tipped, is a different case. The third is that a service charge levied by the establishment on its own account was not decided. What the Court approved, from Rambagh Palace Hotel, is that the true character of tips is not a payment made by the management but a transfer of what is collected from the customer and paid to the staff; that passage speaks of customers paying tips to the management in the shape of service charges, so the line has to be drawn on whose receipt the money is rather than on what the bill calls it. One question was left open in terms: the Court said it was unnecessary to go into the nature of interest under section 201(1A), deciding the point instead on Eli Lilly, that interest can only be levied where a person is declared an assessee in default. On the years this still governs. The Income-tax Act, 1961 was repealed on 1 April 2026 by section 536(1) of the Income-tax Act, 2025, and section 536(2)(c) continues it for proceedings pending, and proceedings initiated on or after that date, in respect of any tax year beginning before 1 April 2026. Survey-based deduction proceedings for those years are live and this judgment decides them. For a credit or payment on or after 1 April 2026 the deduction provision for salary is section 392 of the 2025 Act and section 398 takes the place of section 201. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
The judgment runs to thirty-eight numbered paragraphs and the sentences quoted here are located by those numbers. It is dated 26 April 2016; 28 April 2016 is also in circulation, and both refer to this one decision. The cause title is worth getting right because the appeals ran both ways. ITC Limited, Gurgaon was the appellant against the Commissioner of Income Tax (TDS), Delhi, and there were also Revenue appeals in the batch, arising out of SLP (Civil) Nos. 9587-9589 of 2012, which were dismissed. The bench was Kurian Joseph and R.F. Nariman, JJ. The judgment of the Delhi High Court under appeal is dated 11 May 2011 and it was set aside in toto, not in part - which matters, because that High Court judgment had gone against the assessee only on credit card tips and the department sometimes still cites the cash-tip half of it as though it survived. Three things this case is not authority for. It is not authority that nothing routed through an employer's account can be salary; the reasoning is that an employer is a person who employs another under a contract of employment, and that section 15(b) has reference to that contract, so the question is always what the contract entitles the employee to. It is not authority on a service charge added by the establishment on its own account. And it is not authority that the employees escape - the Court placed the amount under section 56(1) in their hands, following Emil Webber, and counsel for the assessees accepted that the tips are taxable in the employees' hands, so a hotel relying on this page should not tell its staff the tip is tax free. The English cases are handled carefully in the judgment and should be handled carefully in argument. Calvert v Wainwright and Moorhouse v Dooland were decided under Schedule E, which does not carry the employer nexus that sections 15 and 17 carry, and the Court said so. Wrottesley v Regent Street Florida Restaurant was approved. Hochstrasser v Mayes is the one the Court actually used, because paragraph 2 of Schedule E comes close to section 15 and carries a proximity test. On penalty. Penalty under section 271C was initiated by separate proceedings and formed no part of the appeal. The Court recorded that by an order dated 19 June 2013 penalty had been levied against ITC in the civil appeals arising from SLP (Civil) Nos. 20822-20824 of 2011, and said that since the High Court judgment was being set aside in toto, none of the observations on penalty would bind either of the parties. The judgment does not decide what happens where the contract of employment or a settlement gives the employee an enforceable claim to a share of the pooled tips - the whole holding rests on the finding that no such vested right existed. It decides nothing about a service charge levied by the establishment on its own account and then distributed; the passage the Court approved from Rambagh Palace Hotel speaks of customers paying tips to the management in the shape of service charges, so the case supplies no rule that turns on the label the bill uses, and the question is always whose receipt the money is. It does not decide whether the employees were in fact assessed on the amounts, or what follows if they were not; counsel for the assessees accepted that the tips are taxable in the employees' hands as income from other sources, and the Court recorded that it was nobody's case otherwise. It leaves undecided, in terms, the nature of interest under section 201(1A), holding only that the interest cannot survive the absence of a default. The machinery argument - that an employer cannot predicate what each employee will receive, met by the answer that section 192(3) permits monthly estimates and adjustment - was argued at length and not resolved, the Court saying it was unnecessary to go into the various other submissions made on both sides. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The appeals filed by the assessees were allowed and the Revenue's connected civil appeals were dismissed: "The appeals filed by the assessees are, therefore, allowed and civil appeals arising out of SLP (Civil) Nos.9587-9589 of 2012 filed by Revenue are dismissed. The judgment of the High Court is set aside with no order as to costs." Tips do not fall within section 15(b) at all, because there is no vested right in the employee to claim any amount of tip from his employer and the amount has no reference to the contract of employment; the employer receives tips in a fiduciary capacity as trustee and is only a conduit between the customer and the employee. Income from tips is chargeable in the hands of the employees as income from other sources, so section 192 is not attracted on these facts. Because the appellants are outside section 192 they cannot be stated to be assessees in default, and no question of interest under section 201(1A) arises. Since the High Court judgment was set aside in toto, none of its observations on penalty bind either party.
TaxSphere, “ITC Ltd v CIT (TDS)”, https://taxnotice.vittsphere.com/caselaw/case/itc-ltd-v-cit-tds-tips-are-not-salary-under-192/ (validity last checked 2026-09-23)
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