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

ITA 6431/MUM/2025Status: DisposedITAT Mumbai19 January 2026AY 2017-1833 pages
AI SummaryDismissed

What did the Tribunal hold?

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

What were the facts?

The assessee, a multi-state co-operative bank, failed to deduct TDS on interest paid to other co-operative societies. 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 mandate 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 and are disposed of by this common order for the sake of convenience

The order continues below.

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