THE SAHLON MULTIPURPOSE CO0OP AGRI SERVICE SOCIEY LTD,NEWSHAHAR vs. INCOME TAX OFFICER ( TDS), JALANDHAR

ITA 334/ASR/2025Status: DisposedITAT Amritsar25 June 2026AY 2016-1711 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the exemption under Section 194A(3)(v) applies to payments made by a cooperative society to its members, and the definition of 'member' under the Punjab Cooperative Societies Act includes nominal and associate members. Therefore, TDS was not required on interest paid to such members.

What were the facts?

The assessee, a cooperative agriculture service society, paid interest to its members, including nominal and associate members, without deducting TDS. The AO treated the assessee in default for non-compliance with Section 194A(3)(i)(d) of the Income Tax Act.

What were the issues?

Whether TDS is required on interest paid by a cooperative society to its nominal and associate members, and if a CBDT circular can override the exemption provided in Section 194A(3)(v).

Which sections of the Income-tax Act were involved?

Section 194A,Section 201,Section 201(1A),Section 119

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: SH. MANOJ KUMAR AGGARWAL & SH. UDAYAN DASGUPTA

For Appellant: Adv. :
For Respondent: Smt. Ratinder Kaur, Sr. D.R
Hearing: 06.04.2026Pronounced: 25.06.2026

Per Udayan Dasgupta, J.M.:

This appeal is filed by the assessee against the order of the ld. CIT (A) NFAC, Delhi dated 27.02.2025 passed u/s 250 of the Income Tax Act, 1961 (henceforth the Act) which has emanated from the order of the ITO, TDS, Jalandhar dated 19.01.2023 passed u/s 200A(1) of the Act.

2 Assessment Year: 2016-17

2.

Grounds of appeal taken by the assessee in Form No. 36 are as follows:

“1. That the order of Ld. Addl/JCIT (Appeals)-NFSC Chennai, is against law & facts of the case.

2.

That the Ld. Addl/JCIT (Appeals)-NFAC, Chennai has erred in law & facts of the case in confirming the action o

The order continues below.

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