STATE BANK OF INDIA,JAMNAGAR vs. ASSISTANT REGISTRAR, RAJKOT

ITA 199/RJT/2026Status: DisposedITAT Rajkot24 September 2026AY 2017-185 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee cannot be treated as an assessee in default for non-deduction of TDS on Leave Travel Concession when it was operating under binding interim judicial directions. The demand raised under section 201(1) and 201(1A) was directed to be deleted.

What were the facts?

The assessee, State Bank of India, treated Leave Fare Concession and Leave Travel Concession provided to employees as exempt under section 10(5) and did not deduct TDS under section 192. The DCIT treated the assessee as an assessee in default under section 201(1) and raised a demand.

What were the issues?

Whether the assessee can be treated as an assessee in default for non-deduction of TDS on Leave Travel Concession when bound by judicial orders. Whether the demand under section 201(1) is sustainable in such circumstances.

Which sections of the Income-tax Act were involved?

Section 10(5),Section 192,Section 201(1),Section 201(1A),Section 271(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Rajkot Bench, Rajkot

Before: Dr. Arjun Lal Saini & Shri Sonjoy Sarma

For Appellant: Shri Maulik Kansara , Ld. AR
For Respondent: Shri Ganesh Iyer, Ld. Sr. DR
Hearing: 23/09/2026Pronounced: 24/09/2026

Per, Shri Sonjoy Sarma, JM: Captioned appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), ADDL/JCIT(A)-2, Siliguri vide order dated 11.12.2025 passed for Assessment Year (AY) 2017-18, which in turn arises out of an order passed by DCIT Circle, TDS, Rajkot u/s. 201 of the Act, dated 20.10.2023. State Bank of India v.

The order continues below.

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