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

ITA 6441/MUM/2025Status: DisposedITAT Mumbai19 January 2026AY 2018-1933 pages
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What did the Tribunal hold?

The Tribunal held that the assessee was not required to deduct TDS on interest paid to other co-operative societies based on the exemption provided under Section 194A(3)(v) of the Income-tax Act. The specific provisions relied upon by the revenue were not applicable in this context.

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 treated the bank as an assessee in default and levied tax and interest.

What were the issues?

Whether a co-operative bank is required to deduct TDS on interest paid to other co-operative societies, considering the exemptions under Section 194A(3)(v).

Which sections of the Income-tax Act were involved?

Section 194A,Section 201(1),Section 201(1A),Section 194A(3)(v),Section 194A(3)(i)(b),Section 194A(3)(viia)(b)

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Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI BIJAYANANDA PRUSETH

For Appellant: Shri Nitesh Joshi a/w Shri Harsh Kothari, Mr. Virabhadra S. Mahajan, Sr. DR
For Respondent: Shri Nitesh Joshi a/w Shri Harsh Kothari, 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

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