CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MANORI BRANCH),MUMBAI vs. ITO (TDS) 1(1)(4), MUMBAI

ITA 6430/MUM/2025Status: DisposedITAT Mumbai19 January 2026AY 2018-1933 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the co-operative bank was covered by specific provisions of Section 194A(3)(i)(b) and 194A(3)(viia)(b) of the Act, not the general provision of Section 194A(3)(v). Therefore, it was liable to deduct TDS on interest payments above the threshold.

What were the facts?

The assessee, a co-operative bank, failed to deduct TDS on interest paid to other co-operative societies and a trust. The Assessing Officer held the bank liable for TDS and interest under sections 201(1) and 201(1A) of the Income-tax Act.

What were the issues?

Whether a co-operative bank is exempt from deducting TDS on interest paid to other co-operative societies under Section 194A(3)(v) or if specific provisions apply. Whether the interest paid to a trust, which was offered for taxation by the trust, necessitates TDS deduction.

Which sections of the Income-tax Act were involved?

Section 194A,Section 201(1),Section 201(1A),Section 80P(2)(d)

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Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI BIJAYANANDA PRUSETH

For Appellant: Shri Nitesh Joshi a/w Shri Harsh Kothari
For Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Hearing: 18/12/2025Pronounced: 19/01/2026

PER BENCH: These 66 appeals filed by the assessee emanate from the orders passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act') by the Addl./JCIT (A) – 10, Delhi, Office of the Commissioner of Income-tax (Appeals), dated 05.09.2025 [in short, ‘CIT(A)'] for the assessment years (AYs) 2016-17, 2017-18, 2018-19 and 2019-20. Since the issues in these appeal are similar except variance in amounts, therefore, with consent of both parties, these appeals were heard together a

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