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

ITA 6434/MUM/2025Status: DisposedITAT Mumbai19 January 2026AY 2019-2033 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee, a cooperative bank, was obligated to deduct tax at source on interest paid to cooperative societies that were not members, as specific provisions override general exemptions. The assessee's claim of exemption under Section 194A(3)(v) was rejected.

What were the facts?

The assessee, a multi-state cooperative bank, failed to deduct TDS on interest paid to other cooperative societies. The Assessing Officer held that the assessee, being a cooperative bank, was not exempt from TDS provisions under Section 194A.

What were the issues?

Whether a cooperative bank is required to deduct TDS on interest paid to other cooperative societies, and if exemptions under Section 194A(3)(v) apply to cooperative banks.

Which sections of the Income-tax Act were involved?

Section 194A,Section 201(1),Section 201(1A)

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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 and brevity. ITA No.6038/M/2025 for AY 2016-17 is

The order continues below.

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