INCOME TAX OFFICER, MUMBAI vs. SYNDICATE BANK (NOW MERGED WITH CANARA BANK), MUMBAI

ITA 6763/MUM/2025Status: DisposedITAT Mumbai27 April 2026AY 2012-134 pages
AI SummaryDismissed

What were the facts?

The assessee bank paid interest on fixed deposits to the Slum Rehabilitation Authority (SRA) without deducting tax at source. The Assessing Officer treated the bank as an assessee in default and levied demand and interest.

What did the Tribunal hold?

The Tribunal held that the assessee was not liable to deduct tax at source on interest paid to SRA, following a coordinate bench decision. Therefore, the assessee cannot be treated as an assessee in default.

What were the issues?

Whether the assessee was liable to deduct tax at source under Section 194A on interest paid to SRA, and whether the order of the Assessing Officer was barred by limitation.

Which sections of the Income-tax Act were involved?

Section 194A,Section 201(1),Section 201(1A),Section 201(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI JAGADISH

For Appellant: Shri S. Ananthan – CA &
For Respondent: Shri Mahesh Parwani - SR. AR
Hearing: 23.04.2026Pronounced: 27.04.2026

Per: SHRI JAGADISH, A.M.:

1.

This appeal is filed by the Revenue against the order dated 29.08.2025 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for the assessment year 2012– 13, arising out of the order passed under section 201(1) read with section 201(1A) of the Income-tax Act, 1961. 2. Briefly stated, the facts of the case are that the assessee, a Public Sector Undertaking engaged in the business of banking, during the year under consideration paid interest on fixed deposits amounting to ₹6,18,90,780/- to Slum Rehabilitation Authorit

The order continues below.

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