MAHESHMATI NAGRIK SAHKARI BANK LTD,MANDLA vs. INCOME TAX OFFICER, MANDLA WARD, MANDLA, MANDLA

ITA 44/JAB/2025Status: DisposedITAT Jabalpur22 September 2026AY 2015-169 pages
AI SummaryAllowed

What were the facts?

A co-operative bank faced disallowance of interest expenses amounting to ₹1,04,96,367/- under Section 40(a)(ia) for allegedly not submitting a complete list of depositors and Form 15H/15G. The assessee contended that these documents were duly submitted to the tax authorities.

What did the Tribunal hold?

The tribunal held that once Form 15G/15H are received by the deductor, the liability to deduct tax at source under Section 194A ceases as per Section 197A. Therefore, Section 40(a)(ia) cannot be invoked merely for non-filing these forms with the designated authority, and the disallowance was set aside.

What were the issues?

Whether disallowance under Section 40(a)(ia) is applicable when Form 15G/15H are obtained from depositors, thereby negating TDS liability under Section 194A read with Section 197A, even if these forms were not filed with the designated authority.

Which sections of the Income-tax Act were involved?

Section 40(a)(ia),Section 194A,Section 197A,Section 272A(2)(f)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH, MP

Before: HON’BLE SHRI KUL BHARAT & SHRI G.D. PADMAHSHALI

For Appellant: Mr H.S. Modh [‘Ld. AR’]
For Respondent: Mr N.M. Prasad [‘Ld. DR’]
Pronounced: 22/09/2026

PER G. D. PADMAHSHALI; The first appellate DIN & Order No. ITBA/NFAC/S/250/2024-

25/1071277596(1) dt. 17/12/2024 passed by National Faceless

Appeal Centre, Delhi [‘Ld. NFAC’] u/s 250 of the Income Tax

Act, 1961 [‘the Act’] by present appeal is challenged by the assessee u/s 253(1) of the Act which dealt with assessment order

passed u/s 143(3) of the Act by the Income Tax Officer, Madla

[‘Ld. AO’] for assessment year 2015-16 [‘AY’].

ITAT-Jabalpur Maheshmati Nagrik Sahkari Bank Ltd. Vs ITO ITA No. 044/JAB/2025 AY: 2015-16

2.

The facts of the case succinctly stated are that;

2.

1 the assessee is Co-operative Bank engaged in fin

The order continues below.

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