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The Tribunal held that an assessment order passed against a dissolved company, which has ceased to exist, is a nullity. Such an order cannot give rise to any right or liability under the Income Tax Act.
The High Court upheld the orders of the CIT(A) and ITAT, stating that the funds were either Government of India's money (exempt under Section 196) or JKSRRDA was a body wholly financed by the Government (exempt under Section 194A(3)(iii)(f) read with Notification No. 3489).
The Tribunal held that the Jammu Development Authority (JDA), being a corporation established under a State Act, was exempt from TDS deduction under Section 194A of the Income Tax Act. Therefore, the assessee-bank was not obligated to deduct TDS on interest payments made to JDA.
The Tribunal held that the Commissioner had not brought on record any material to prove the fees structure was in-genuine or that the Trust's activities were for non-charitable purposes. The Supreme Court's judgment in Queen's Educational Society was cited as covering the issue.