M/S. DHARMAPURI DISTRICT CENTRAL CO-OPERATIVE BANK LIMITED,KRISHNAGIRI vs. ITO, TDS WARD, HOSUR, HOSUR

ITA 2131/CHNY/2026Status: DisposedITAT Chennai06 August 2026AY 2020-2117 pages
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What were the facts?

The assessee bank was treated as an assessee in default for failing to deduct tax at source under Section 194N on cash withdrawals by cooperative societies. The bank argued that these withdrawals were for government welfare schemes and agricultural loans, and that the societies acted as business correspondents.

What did the Tribunal hold?

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

What were the issues?

Whether the enhanced threshold for TDS on cash withdrawals under Section 194N applies retrospectively to cooperative societies, and if certain withdrawals are exempt from TDS.

Which sections of the Income-tax Act were involved?

Section 194N,Section 201(1),Section 201(1A)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: MS. PADMAVATHY S & SHRI MANU KUMAR GIRI

Hearing: 06.08.2026

PER MANU KUMAR GIRI, JM: The captioned eighteen appeals filed by the assessee are directed against separate orders passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, all dated 13.01.2026 arising out of orders passed by the Income Tax Officer (TDS), Hosur under sectio

The order continues below.

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