Coimbatore\nDistrict Central Co-operative Bank Ltd. v. ITO

382 ITR 266High Court2016#7159 most cited
16

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Sections most often in play

Section 10Section 194ASection 194A(1)Section 194A(3)Section 194A(3)(i)Section 194A(3)(i)(b)Section 194A(3)(v)Section 194A(3)(viia)

Issues it is cited on

section 80p(i)section 194a(3)(viia)(b)section 194a(3)(viia)(a)section 194a(3)(i)(b)section 194a(3)(i)section 194(3)(v)section 194a(1)section 194a(3)(v)section 194a(3)short deduction of taxinterest on securitiessection 2(19)

Judgments citing Coimbatore\nDistrict Central Co-operative Bank Ltd. v. ITO

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2381/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…ording to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n42. In section 194…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2380/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…ding to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\n\"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n\n42. In section…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2379/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…ording to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n42. In section 194A…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2378/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…ording to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n42. In section 194…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2377/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)

…ding to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\n\"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n\n42. In section…

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

In the results, all the appeals of the assessee are dismissed

ITA 2376/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Rajeev Waglay,ARFor Respondent: Mr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…according to us not correct and it may be noted that section 194A(3)(v) is a general provision which encompasses with it co-operative society as a whole. 7.2 Hon’ble Madras High Court in the case of Coimbatore District Central Co-operative Bank Ltd. vs. ITO (382 ITR 266) had an occasion to go into the provisions of sec. 194A(3) of the Act which is similar to the issue before us. In that case, after elaborate discussion, the High Court opined as under: “61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended. Clause 42 of the Finance Bill, 2015, reads as follows: 42. In section 194A of t…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2375/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(3)(v)Section 2(19)Section 201(1)

…ording to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\"61. With effect from June 1, 2015, sub-section (3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n42. In section 19…

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

In the results, all the appeals of the assessee are\ndismissed

ITA 2374/MUM/2025[2016-17]Status: DisposedITAT Mumbai15 Jul 2025AY 2016-17
For Appellant: \nShri Rajeev Waglay,ARFor Respondent: \nMr. Virabhadra S. Mahajan, (Sr. DR)
Section 194ASection 194A(1)Section 194A(3)(v)Section 2(19)Section 201(1)

…ording to us not correct and it may be noted\nthat section 194A(3)(v) is a general provision which encompasses with it\nco-operative society as a whole.\n7.2 Hon'ble Madras High Court in the case of Coimbatore\nDistrict Central Co-operative Bank Ltd. vs. ITO (382 ITR 266)\nhad an occasion to go into the provisions of sec. 194A(3) of the Act which\nis similar to the issue before us. In that case, after elaborate discussion,\nthe High Court opined as under:\n\"61. With effect from June 1, 2015, sub-section(3) of section 194A stands amended.\nClause 42 of the Finance Bill, 2015, reads as follows:\n42. In section 194…

THE KUPPAM CO-OPERATIVE TOWN BANK LIMITED ,KUPPAM vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HYDERABAD

Appeal is allowed in above terms

ITA 1003/HYD/2019[2013-14]Status: DisposedITAT Hyderabad02 Sept 2021AY 2013-14

Bench: Shri S.S.Godara & Shri Laxmi Prasad Sahu

For Appellant: NoneFor Respondent: Sri Waseem Ur Rehman, D.R
Section 143(3)Section 194ASection 194A(3)(i)Section 194A(3)(v)Section 255(4)Section 40

…e assessee, the addition of Rs5,15,522/- added by the assessee as no TDS was made on the interest payments to its members, following the decision of the hon’ble high court of Madras in the case of Coimbatore District Central Co-operative Bank Ltd; reported in 382 ITR 266 (Mad)(HC)”. 2. Coming to the sole issue of applicability of sec 194A(3)(v) qua the assessee/ a co-operative society’s interest payments made to its members, we note that this tribunal’s coordinate bench’s order dated 25..06.2021 in ITA 482 & 483/Hyd/2018 in ACIT vs. Tirupathi Co-operative Bank Ltd. Holds in light of the Finance Act, 2015’s prosp…

ACIT CIRCLE 1, OOTY vs. NILGIRI DISTRICT CENTRAL CO-OPERATIVE BANK LTD., OOTACAMUND

In the result, the appeal of the Revenue is allowed for statistical purpose

ITA 1851/CHNY/2018[2014-15]Status: DisposedITAT Chennai29 Oct 2018AY 2014-15

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

For Appellant: Shri. M.Srinivasa Rao, IRS, CIT
Section 194A

…आयकर अपील"य अ"धकरण, ’ए’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL, ‘A’ BENCH : CHENNAI "ी अ"ाहम पी. जॉज", लेखा सद"य एवं "ी धु"वु" आर.एल रे"डी, "या"यक सद"य के सम" । [BEFORE SHRI ABRAHAM P. GEORGE, ACCOUNTANT MEMBER AND SHRI DUVVURU RL REDDY, JUDICIAL MEMBER] आयकर अपील सं./I.T.A. No.1851/CHNY/2018. "नधा"रण वष" /Assessment year : 2014-2015. The Assistant Commissioner Vs. M/s. Nilgiri District Central Co- of Income Tax, operative Bank Ltd, Circle 1, No.5, Charing Cross Road, Ooty. Ootacamund -1 [PAN AAALT 0073E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri. M.Srinivasa R…

VIRUDHUNAGAR CENTRAL DISTRICT CO-OPERATIVE BANK,VIRUDHUNAGAR vs. ITO, VIRUDHUNAGAR

In the result, the appeals of the assessee for both the years are

ITA 2056/CHNY/2014[2013-14]Status: DisposedITAT Chennai09 Oct 2018AY 2013-14

Bench: Shri N.R.S. Ganesan, Shri Abraham P. George & Shri A.Mohan Alankamony] आयकर अपील सं./I.T.A. Nos.2055 & 2056/Chny/2014 "नधा"रण वष" /Assessment Years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, Tds Ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [Pan Aaaau 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Respondent: Shri. Sailendra Mamidi, PCIT
Section 194ASection 194A(3)Section 201

…IN THE INCOME TAX APPELLATE TRIBUNAL CHENNAI SPECIAL BENCH ‘’C’’ : CHENNAI [BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER, SHRI ABRAHAM P. GEORGE, ACCOUNTANT MEMBER AND SHRI A.MOHAN ALANKAMONY, ACCOUNTANT MEMBER] आयकर अपील सं./I.T.A. Nos.2055 & 2056/CHNY/2014 "नधा"रण वष" /Assessment years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, TDS ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [PAN AAAAU 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. C. Maruthappan, C.A. अपीलाथ" क" ओर से/ Appellant by ""यथ" क" ओर से /Respondent by : Shri. S…

VIRUDHUNAGAR CENTRAL DISTRICT CO-OPERATIVE BANK,VIRUDHUNAGAR vs. ITO, VIRUDHUNAGAR

In the result, the appeals of the assessee for both the years are

ITA 2055/CHNY/2014[2012-13]Status: DisposedITAT Chennai09 Oct 2018AY 2012-13

Bench: Shri N.R.S. Ganesan, Shri Abraham P. George & Shri A.Mohan Alankamony] आयकर अपील सं./I.T.A. Nos.2055 & 2056/Chny/2014 "नधा"रण वष" /Assessment Years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, Tds Ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [Pan Aaaau 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Respondent: Shri. Sailendra Mamidi, PCIT
Section 194ASection 194A(3)Section 201

…IN THE INCOME TAX APPELLATE TRIBUNAL CHENNAI SPECIAL BENCH ‘’C’’ : CHENNAI [BEFORE SHRI N.R.S. GANESAN, JUDICIAL MEMBER, SHRI ABRAHAM P. GEORGE, ACCOUNTANT MEMBER AND SHRI A.MOHAN ALANKAMONY, ACCOUNTANT MEMBER] आयकर अपील सं./I.T.A. Nos.2055 & 2056/CHNY/2014 "नधा"रण वष" /Assessment years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, TDS ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [PAN AAAAU 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. C. Maruthappan, C.A. अपीलाथ" क" ओर से/ Appellant by ""यथ" क" ओर से /Respondent by : Shri. S…

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

ITA 826/CHNY/2017[2014-15]Status: DisposedITAT Chennai12 Jun 2017AY 2014-15

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194ASection 194A(1)Section 194A(3)Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)

…squarely covered by the decision of the Hon’ble Jurisdictional High Court in the case of M/s.Coimbatore Central Co- operative Bank Ltd. vs. the TDS Officer in Tax Case Appeal Nos.588 to 643, 647 to 688, 744 to 750, 942 to 948, 969 to 982 of 2015 reported in 382 ITR 266 (Madras) wherein in Para No.64 of the Order, it has been held that the amendment made to Sec.194A in respect of TDS was prospective in nature w.e.f. 01.06.2015. 4. In reply, the Ld.DR vehemently supported the order of the AO. It was a submission that in view of the provisions of Sec.194A(3), it was mandatory on the assessee to deduct the TDS on t…

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

ITA 825/CHNY/2017[2013-14]Status: DisposedITAT Chennai12 Jun 2017AY 2013-14

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194ASection 194A(1)Section 194A(3)Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)

…squarely covered by the decision of the Hon’ble Jurisdictional High Court in the case of M/s.Coimbatore Central Co- operative Bank Ltd. vs. the TDS Officer in Tax Case Appeal Nos.588 to 643, 647 to 688, 744 to 750, 942 to 948, 969 to 982 of 2015 reported in 382 ITR 266 (Madras) wherein in Para No.64 of the Order, it has been held that the amendment made to Sec.194A in respect of TDS was prospective in nature w.e.f. 01.06.2015. 4. In reply, the Ld.DR vehemently supported the order of the AO. It was a submission that in view of the provisions of Sec.194A(3), it was mandatory on the assessee to deduct the TDS on t…

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

ITA 824/CHNY/2017[2010-11]Status: DisposedITAT Chennai12 Jun 2017AY 2010-11

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194ASection 194A(1)Section 194A(3)Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)

…squarely covered by the decision of the Hon’ble Jurisdictional High Court in the case of M/s.Coimbatore Central Co- operative Bank Ltd. vs. the TDS Officer in Tax Case Appeal Nos.588 to 643, 647 to 688, 744 to 750, 942 to 948, 969 to 982 of 2015 reported in 382 ITR 266 (Madras) wherein in Para No.64 of the Order, it has been held that the amendment made to Sec.194A in respect of TDS was prospective in nature w.e.f. 01.06.2015. 4. In reply, the Ld.DR vehemently supported the order of the AO. It was a submission that in view of the provisions of Sec.194A(3), it was mandatory on the assessee to deduct the TDS on t…

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

ITA 823/CHNY/2017[2009-10]Status: DisposedITAT Chennai12 Jun 2017AY 2009-10

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194ASection 194A(1)Section 194A(3)Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)

…squarely covered by the decision of the Hon’ble Jurisdictional High Court in the case of M/s.Coimbatore Central Co- operative Bank Ltd. vs. the TDS Officer in Tax Case Appeal Nos.588 to 643, 647 to 688, 744 to 750, 942 to 948, 969 to 982 of 2015 reported in 382 ITR 266 (Madras) wherein in Para No.64 of the Order, it has been held that the amendment made to Sec.194A in respect of TDS was prospective in nature w.e.f. 01.06.2015. 4. In reply, the Ld.DR vehemently supported the order of the AO. It was a submission that in view of the provisions of Sec.194A(3), it was mandatory on the assessee to deduct the TDS on t…