( 1 ) THIS application involves interpretation of the provisions of Section 194a (3) (ix) of the Income-tax Act, 1961 regarding deduction at source of the income-tax payable on the interest received by the claimants on the compensation received by them pursuant to the award of the Motor Accident Claims Tribunal.

( 2 ) THIS application is filed by the heirs of deceased Prafulchandra Narbheram Ladhani, who had filed Motor Accident Claim Petition before the Motor Accident Claims Tribunal for claiming compensation of Rs. 20 lakhs on account of death of Prafulchandra Narbheram Ladhani (hereinafter referred to as "the deceased") on 1. 4. 1991 in a motor vehicle accident between an Ambassador car in which the deceased was travelling and a public carrier truck. The claim petition was filed by Smt. Hansaguri, widow of the deceased, four daughters (claimant Nos. 2 to 5) and son Naresh (claimant No. 6 ). 2. 1 The original claim petition being MAC Petition No. 743 of 1991 was filed on 30. 9. 1991 before the Motor Accident Claims Tribunal at Junagadh. Upon constitution of the Motor Accident Claims Tribunal at Veraval, the said petition was transferred to Veraval in the year 1999