M/S. THE COIMBATORE DISTRICT CENTRAL CO-OP. BANK LTD.,COIMBATORE vs. ITO, TDS WARD-2,, COIMBATORE

ITA 1004/CHNY/2025Status: DisposedITAT Chennai12 August 2025AY 2020-21Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI JAGADISH (Accountant Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee's argument that PACCS acted as agents or business correspondents and thus the transactions were excluded from Section 194N was not supported by evidence. The exclusion under the proviso to Section 194N for business correspondents was reversed.

What were the facts?

The assessee, a cooperative bank, did not deduct TDS under Section 194N on cash withdrawals exceeding Rs. 1 crore made by Primary Agricultural Cooperative Societies (PACCS) for disbursing government schemes like Pongal gift hampers. The AO treated the assessee in default, raising a demand for TDS and interest.

What were the issues?

Whether TDS under Section 194N was applicable on cash withdrawals by cooperative societies acting as conduits for government scheme disbursements, and if they qualified for exclusions as business correspondents.

Which sections of the Income-tax Act were involved?

Section 133A(2A),Section 194N,Section 201,Section 201(1A),Section 192,Section 198

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Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI JAGADISH

Hearing: 19.06.2025Pronounced: 12.08.2025

PER JAGADISH, A.M : Aforesaid appeal filed by the assessee for Assessment Year (AY) 2020-21 arises out of the order of Learned Commissioner of Income Tax, Appeal, Addl./JCIT(A)-2, Mumbai [hereinafter “Addl. CIT(A)”] dated 10.02.2025 in the matter of assessment framed by the Assessing Officer [AO] u/s. 201/201(1A) of the Income-tax Act,1961 (hereinafter “the Act”) on 12.03.2020. The Coimbatore District Central Co-op. Bank Ltd. :- 2 -:

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