N.K.Sud, J.

1. This order will dispose of two appeals, viz., I. T. A. Nos. 194 and 195 of 2004 filed by the assessee under Section 21 of the Interest-tax Act, 1974 (for short "the Act"), read with Section 260A of the Income-tax Act, 1961, against the common order of the Income-tax Appellate Tribunal, Amritsar Bench, Amritsar (for short "the Tribunal"), dated March 31, 2004, relating to the assessment years 1992-93 and 1993-94.

2. For the assessment year 1992-93, the assessee had filed its return under the Act on February 21, 1992, declaring chargeable interest as under :

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3. This return was subsequently revised on November 10, 1993, declaring chargeable interest at nil. The assessee claimed that the hire-purchase charges were not covered under the provisions of Section 4(2) of the Act as the same pertained to arrangements for use of finance. It was contended that the charges could not termed as interest as in such arrangements, no principal sum is advanced or lent by the hire-purchase company to the hirer of the vehicle whereas the definition of interest under the Act envisages giving of loan and advance. Reliance for this purpose was placed on the instructions