ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

ITA 648/COCH/2025Status: DisposedITAT Cochin29 October 2025AY 2022-23Bench: SHRI INTURI RAMA RAO (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the bank cannot be treated as an assessee in default because it had complied with section 197A(1C) by obtaining Form 15G/H. There is no obligation on the bank to verify the taxable income of the depositors. The matter was remanded to the AO for verification of claims regarding Form 15G.

What were the facts?

The appellant bank conducted a survey under section 133A, where it was found that tax was not deducted at source under section 194A on interest payments to senior citizens who provided Form 15G/H. The TDS officer treated the bank as an assessee in default and demanded tax under section 201(1A). The CIT(A) dismissed the appeal.

What were the issues?

Whether the appellant bank is an assessee in default for not deducting tax at source on interest paid to senior citizens who submitted Form 15G/H, and whether the matter should be remanded for verification of Form 15G submissions.

Which sections of the Income-tax Act were involved?

Section 133A,Section 194A,Section 201(1A),Section 197A(1C),Section 197A(1A),Section 191,Section 197A,Section 201

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Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM & SHRI ANIKESH BANERJEE, JM

For Appellant: Shri Anandan, CA
For Respondent: Smt. Leena Lal, Sr. D.R
Hearing: 27.10.2025Pronounced: 29.10.2025

Per: Inturi Rama Rao, AM These appeals filed by the assessee are directed against the orders of the Commissioner of Income Tax (Appeals)-2, Chennai [CIT(A)] dated 23.07.2025 for Assessment Years (AY) 2018-19 to 2020-21 & 2022-23. 2. Since identical issues and facts are involved in these appeals, they are heard together and disposed of by this common order.

3.

For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 645/Coch/2025 for AY 2018-19 are stated herein. Esaf Small Finance Bank Ltd.

4.

Brief facts of the case are that the appellant is a company engaged in the business of banking. The Income T

The order continues below.

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