T.VENKATAPPA, O.V.SUBRAMANIAN
H. S. SALIAN – Appellant
Versus
FOURTH INCOME-TAX OFFICER – Respondent
Per Shri T. Venkatappa, Judicial Member - Since common points are involved in these appeals for three years, they are being disposed of together. The assessee is an employee of LIC. He had taken loan from LIC for house construction. The loan was granted at a concessional rate of interest of 5 per cent. The ITO was of the view that the LIC charged higher rate of interest of 10 per cent to its clients on the loans advanced to them, whereas lower rate of interest is charged to its employees on the loans advanced for construction of house. Thus, the assessee enjoyed a concession which is to be treated as a perquisite. Thus, the ITO added 5½ per cent interest as perquisite which came to Rs. 1,727. In appeal, the AAC held that as per section 17(2)(iii) of the Income-tax Act, 1961, perquisite includes value of any concession or amenity granted or provided free of cost or at concessional rate by any employer to an employee whose income under the head "Salaries", exclusive of the value of all benefits or amenities not provided for by way of monetary payment exceeds eighteen thousand rupees. The LIC advances loans to the employees at a concessional rate of 5 per cent whereas it charges
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