Which sections of the Income Tax Act does Jalgaon District Central Co-Operative Bank Ltd. v. Union of India come up under?

It is most often cited in judgments turning on Section 148, Section 194A, Section 194A(3)(v), Section 40(a)(ia), Section 143(3), Section 147.

Jalgaon District Central Co-Operative Bank Ltd. v. Union of India

Q: How many judgments cite Jalgaon District Central Co-Operative Bank Ltd. v. Union of India?

47 judgments on BharatTax cite Jalgaon District Central Co-Operative Bank Ltd. v. Union of India (265 ITR 423), spanning 2015 to 2025.

265 ITR 423High Court2004#2442 most cited

What is Jalgaon District Central Co-Operative Bank Ltd. v. Union of India authority for?

A CBDT circular restricting the definition of "member" under Section 194A(3)(v) to exclude nominal, associate, or sympathizer members of a co-operative society is invalid. Such a circular conflicts with the provisions of the Act and exceeds the powers granted to the CBDT under Section 119, meaning co-operative banks are not liable to deduct tax at source on interest paid to these members.

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2025.

Also referred to as

Jalgaon District Central Co-operative Bank · 265 ITR 423 · Section 194A(3)(v) · CBDT Circular quashed · definition of member · co-operative society interest · TDS exemption · nominal member · associate member · sympathizer member · Section 119 · ultra vires circular

Sections most often in play

Section 148 Section 194A Section 194A(3)(v)Section 40(a)(ia)Section 143(3)Section 147 Section 201 Section 201(1)

Issues it is cited on

section 194a(3)(i)(b)section 194a(3)(v)section 194a(3)interest on securities section 194a section 201(1)assessee in default section 194 section 80p(2)(a)(i)section 201 section 80p section 19

Judgments citing Jalgaon District Central Co-Operative Bank Ltd. v. Union of India

Himachal Mitra Mandal Co Operative Credit Society Limited, Mumbai vs. Income Tax Officer TDS, Ward 1(2)(3), Mumbai

ITA 777/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarhimachal Mitra Mandal V/S. Income Tax Officer, Tds Cooperative Credit Society बनाम Ward – 1(2)(3), Room No. Limited 419, 4Th Floor, Cumballa Hill C/O Vaish Associates, 106, Mtnl Te Building, Peddar Peninsula Centre, Dr. S.S. Road, Dr. Gopalrao Rao Road, Parel, Mumbai – Deshmukh Marg, Mumbai – 400 012, Maharashtra 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaah0613D Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Ms. Priyanka Jain, ARFor Respondent: Shri Hemanshu Joshi,(Sr. DR)

Section 194A(3)(v)Section 201Section 201(1)Section 250Section 271CSection 5

…gal Uraban Co-op Bank Ltd. v. JCIT order dated 28.08.2013, the Tribunal proceeded on the footing that the aforesaid Circular has been quashed by the Hon'ble Bombay High Court in the case of the Jalgaon District Central Co-operative Bank Ltd. v. Union of India 265 ITR 423 (Bom.) and therefore choose to follow the decision rendered by Pune ITAT SMC in the case of Bhagani Nivedita Sahakari Bank Ltd. (supra). In our view the Hon'ble Bombay High Court in the case of Jalgaon District Central Co- operative Bank Ltd. was dealing with a case of challenge to para 3 of CBDT Circular No. 9 P a g e | 9 A.Y. 2014-15 Himachal…

Commissioner of Income Tax-II, Hyderabad vs. M/S. Patni Telecom Solutions Pvt. Ltd

ITTA/506/2015HC Telangana04 Sept 2025

Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO

Director of Incomd Tax [International Taxation] Hyderabad vs. M/S M W Zander [S] Pte Limited-India Br, Hyderabad

ITTA/503/2015HC Telangana06 Aug 2025

Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO

Assistant Commissioner of Income Tax, Circle 1, Income Tax Department vs. Manorama Coop Bank Ltd, Solapur

In the result, the appeal filed by the Revenue is dismissed

ITA 2157/PUN/2024[2013-14]Status: DisposedITAT Pune22 Apr 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2157/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14 Acit, Cricle-2, Solapur. Vs. Manorama Co-Op. Bank Ltd., Plot 4, 5, 6 Vijapur Road, Indiranagar S.O., Maharashtra- 413004. Pan : Aajfm6823C Appellant Respondent Revenue By : Ms. Shilpa N. C. Assessee By : Shri Pramod S. Shingte Date Of Hearing : 22.01.2025 Date Of Pronouncement : 22.04.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 15.07.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2013-14. 2. The Revenue Has Raised The Following Grounds Of Appeal :- “1) The Ld Cit(A), Nfac Has Erred In Admitting This Exemption U/S 194A (3)(V) To The Assessee For Non-Deduction Of Tds On Interest Credits Of Nominal Members Who Are Not Actual Member As Per Definition Of Person Who Is Eligible For Membership As Per Clause

For Appellant: Shri Pramod S. ShingteFor Respondent: Ms. Shilpa N. C

Section 143(2)Section 143(3)Section 147Section 148Section 194ASection 194A(3)(v)Section 40

…ty, such a person will not be entitled to be covered within section 194A(3)(v). 7. This circular came up for consideration before the Hon’ble jurisdictional High Court in the Jalgaon District Central Cooperative Bank Ltd. and Another Vs. Union of India (2004) 265 ITR 423. The Hon’ble High Court quashed the circular by holding that it restricts the exemption under section 194A(3)(v) only to such members who have joined in application for the registration of the co-operative society and those who are admitted to the membership after the registration in accordance with the bye-laws and rules and excluding nominal, a…

Pristine Jewellery, Mumbai vs. Income Tax Officer, Ward1(2)(4), Surat

In the result, appeal of the assessee is dismissed

ITA 277/SRT/2023[2012-13]Status: DisposedITAT Surat23 Jan 2025AY 2012-13

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.277/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Pristine Jewellery Vs. The Ito, Plot No.20, Midc B/H Khanna Ward-1(2)(4), House, Road No.6, Andheri East, Surat Mumbai-400 096 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaifp6894R (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Unmesh Dalal, Ca Respondent By Shri Mukesh Jain, Sr.Dr Date Of Hearing 05/12/2024 Date Of Pronouncement 23/01/2025

Section 148Section 271BSection 273BSection 44A

…that the notification/circular cannot override the Act. For this, he relied upon the decision in cases of Ganeshdas Khanna vs. ITO and Gujarat Urban Co-op. Bank Federation (Civil Appeal No.11209 of 2002) and Jalgaon District Central Co-operative Bank vs. UoI (265 ITR 423) (Bombay). In subsequent submission dated 25.11.2024, assessee submitted that its started business since last two years. It is a new business and first return of AY. 2011-12 was filed in response to notice u/s 148 of the Act. The appellant had huge losses and no return u/s 139 was filed for AY.2012-13. From AY.2013-14 ITA No.277/SRT/2023/AY.201…

The Raddi Sahakara Bank Niyamitha, Dharwad vs. Assistant Commissioner of Income-Tax, Circle-2(1), Hubballi

In the result, the impugned order could not be faulted with

ITA 538/BANG/2023[2014-15]Status: DisposedITAT Bangalore21 Sept 2023AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Royassessment Year : 2014-15

For Appellant: Shri Parthasarthi and Smt. Sheetal, AdvocatesFor Respondent: Ms. Neera Malhotra, CIT (DR)

Section 143(3)Section 40A

…l Uraban Co- op Bank Ltd. Vs. JCIT order dated 28.8.2013, the tribunal proceeded on the footing that the aforesaid circular has been quashed by the Hon'ble Bombay High Court in the case of The Jalgaon District Central Co-operative Bank Ltd. Vs. Union of India 265 ITR 423 (Born) and therefore chose to follow the decision rendered by Pune ITAT SMC in the case of Bhagani Nivedita Sahakari Bank Ltd. (supra). In our view the Hon'ble Bombay High Court in the case of Jalgaon District Central Cooperative Bank Ltd.'s case was dealing with a case of challenge to para-3 of CBDT Circular No.9 dated 11.9.2002 which tried to i…

Mahesh Urban Co-Operative Bank Ltd, Solapur vs. Assistant Commissioner of Income Tax, Circle-1, Solapur

In the result, the appeal is allowed for statistical purpose

ITA 865/PUN/2023[2016-17]Status: DisposedITAT Pune11 Aug 2023AY 2016-17

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.865/Pun/2023 "नधा"रण वष" / Assessment Year : 2012-13

Section 250Section 40

…ce on the reason that the assessee failed to deduct tax at source from the payment made to non- members on interest paid/credited. The ld. CIT(A) took note of the judgment of the Hon’ble Jurisdictional High Court in Jalgaon DCC Bank Ltd. Vs. Union of India 265 ITR 423 (Bom.) but did not provide any relief for the reason given in para 4.2 that “The appellant has not provided any evidence during the appellate proceeding to prove that the addition relates to members (Including nominal members).” Thus, it is evident that the ld. CIT(A) accepted, in principle, that the deduction of tax at source was not warrante…

The Jhingran Coop Multipurpose Service Society Limited, Nawanshahr vs. Income Tax Officer ( TDS), Jalandhar

ITA 64/ASR/2023[2015-16]Status: DisposedITAT Amritsar20 Jun 2023AY 2015-16

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Shri Rakesh Joshi, AdvocateFor Respondent: Shri Pardeep Kumar, Sr. DR

Section 194ASection 194A(3)(v)Section 201Section 201(1)Section 80P

…as included in the term "members" used in sec.194A(3)(v) of the Act. We notice that paragraph 3 of CBDT Circular (referred supra) has been quashed by Hon'ble Bombay High Court in the case of Jalagaon District Central Co-operative Bank Ltd. Vs. Union of India (265 ITR 423). Accordingly, we hold that the assessee is not liable to deduct tax at source from the interest payments made to Associate members as per sec.194A(3)(v) of the Act.” [ANNEXURE C] Also by the Hon able High Court of Bombay in the case of The Jalgon District Central Bank Vs union of India and Ore. 05/09/2003184 CTR 343. \ANNEXUREDJ 6 I.T.A. No. 6…

Vasavi Credit Co-Operative Society Limited, Bangalore vs. Commissioner of Income Tax Officer (TDS), Bangalore

In the result appeal filed by assessee stands allowed

ITA 335/BANG/2021[2016-17]Status: DisposedITAT Bangalore28 Dec 2021AY 2016-17

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2016-17 M/S. Vasavi Credit Co- Operative Society Ltd., No. 108/1, Sri Chakra, The Commissioner Of East Park Road, Income Tax (Tds), Opp. Vasavi Mahal, Bangalore. Malleshwaram, Vs. Bangalore – 560 003. Pan: Aaajv0152C Appellant Respondent Assessee By : Shri S. Ramasubramanyam, Ca Revenue By : Shri Pradeep Kumar, Cit (Dr) Date Of Hearing : 01-12-2021 Date Of Pronouncement : 28-12-2021 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Order Dated 29/03/2021 Passed By The Ld.Cit (Tds), Bangalore For Ay 2016- 17 On Following Grounds Of Appeal: “1. That The Order Of The Learned Commissioner Of Income- Tax (Tds) In So Far It Is Prejudicial To The Interests Of The Appellant, Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. 2. That The Learned Commissioner Of Income-Tax (Tds) Erred In Law & On Facts In Invoking Provisions Of Section 263 Of The Act With Respect To The Order Passed U/S. 201(1) & 201(1A) On The Ground That They Are Erroneous & Prejudicial To The Interests Of The Revenue.

For Appellant: Shri S. Ramasubramanyam, CAFor Respondent: Shri Pradeep Kumar, CIT (DR)

Section 18Section 194ASection 194A(3)(i)Section 194A(3)(v)Section 201Section 201(1)Section 263

…as included in the term "members" used in sec.194A(3)(v) of the Act. We notice that paragraph 3 of CBDT Circular (referred supra) has been quashed by Hon'ble Bombay High Court in the case of Jalagaon District Central Co-operative Bank Ltd. Vs. Union of India (265 ITR 423). Accordingly, we hold that the assessee is not liable to deduct tax at source from the interest payments made to Associate members as per sec.194A(3)(v) of the Act. 14. In view of the foregoing discussions, we set aside the orders passed by Ld CIT(A) and direct the AO to delete the demand raised u/s 201(1) and 201(1A) of the Act.” 6. In the pres…

Assistant Commissioner of Income Tax, TDS - Circle, Hubballi vs. M/S Shimoga District Co-Operative Central Bank Ltd, Shivamogga

In the result, the appeal by the revenue is dismissed

ITA 295/BANG/2019[2012-13]Status: DisposedITAT Bangalore21 Dec 2021AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012-13

For Appellant: Capt. Pradeep Shoury AryaFor Respondent: Shri L. Bharath, CA

Section 194Section 194ASection 194A(3)(v)Section 197ASection 201(1)

The Assistant Commissioner of Income Tax, Circle - 1(1), Visakhapatnam vs. Visakhapatnam Co-Operative Bank Limited, Visakhapatnam

In the result, appeals filed by the assessee and Revenue are dismissed

ITA 472/VIZ/2018[2015-16]Status: DisposedITAT Visakhapatnam25 Jan 2019AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari –AdvocateFor Respondent: Shri V. Appala Raju - Sr. DR

Section 143(3)Section 32Section 40

…ociety. In the appellant's case all the members are regular members and not any associate or sympathizer member. Even otherwise, the Honble Mumbai High Court in the case of Jalgaon District Central Cooperative Bank Ltd & ANR Vs. Union of India & Others (2003) 265 ITR 423 (Born) has held that no distinction should be made between any nominal member, associate member or sympathiser member, as stated in the CBDT Circular and that interest payment to member of all category could be treated as exempt under section 194A(3)(v) of the Act so as to provide a blanket exemption from TDS provision in respect of interest paym…

The Visakhapatnam Co-Operative Bank Limited, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle -1(1), Visakhapatnam

In the result, appeals filed by the assessee and Revenue are dismissed

ITA 428/VIZ/2018[2015-16]Status: DisposedITAT Visakhapatnam25 Jan 2019AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari –AdvocateFor Respondent: Shri V. Appala Raju - Sr. DR

Section 143(3)Section 32Section 40

The Visakhapatnam Co-Operative Bank Limited, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle -1(1), Visakhapatnam

In the result, appeals filed by the assessee and Revenue are dismissed

ITA 427/VIZ/2018[2014-15]Status: DisposedITAT Visakhapatnam25 Jan 2019AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Ble

For Appellant: Shri G.V.N. Hari –AdvocateFor Respondent: Shri V. Appala Raju - Sr. DR

Section 143(3)Section 32Section 40

Shrinidhi Urban Co-Operative Credit Society Limited, Bagalkot vs. Income Tax Officer Ward-2, Bagalkot

ITA 3090/BANG/2018[2015-16]Status: DisposedITAT Bangalore21 Dec 2018AY 2015-16

Bench: Shri A.K.Garodia, Accounant Member

For Appellant: Shri Ashok G. Mudnur, C. AFor Respondent: Smt. Padmameenakshi, JCIT (DR)

Section 80PSection 80P(2)Section 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC-C” BENCH : BANGALORE BEFORE SHRI A.K.GARODIA, ACCOUNANT MEMBER ITA No. 3090 (Bang) 2018 (Assessment year : 2015 – 16) M/s. Shrinidhi Urban Coop Credit Society Ltd. Appellant Main Road, Rabakavi - 587311, Tal. Jamkhandi, Dist.:- Bagalkot. PAN. AAAAS7029Q Vs The Income Tax Officer, Ward – 2, Bagalkot. Respondent Assessee by : Shri Ashok G. Mudnur, C. A. Revenue by : Smt. Padmameenakshi, JCIT (DR) Date of hearing : 03-12-2018 Date of pronouncement : 21-12-2018 O R D E R PER A. K. GARODIA, A.M.: This appeal is filed by the assessee and it is directed against the order…

Janakhandi Taluka Shree Parshwanath Alpasan Kyatar Pattina Sahakari Sangha Niyamitha, Bagalkot vs. Income Tax Officer Ward-2, Bagalkot

ITA 3083/BANG/2018[2015-16]Status: DisposedITAT Bangalore21 Dec 2018AY 2015-16

Bench: Shri A.K.Garodia, Accounant Member

For Appellant: Shri Ashok G. Mudnur, C. AFor Respondent: Smt. Padmameenakshi, JCIT (DR)

Section 18Section 80PSection 80P(2)Section 80P(2)(a)

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC-A” BENCH : BANGALORE BEFORE SHRI A.K.GARODIA, ACCOUNANT MEMBER ITA No. 3083 (Bang) 2018 (Assessment year : 2015 – 16) M/s. Jamakhandi Taluka Shree Parshwanath Alpasankyatar Pattin Sahakar Sangh Niyamit, Appellant Near Murgod Petrol, Jamkhandi, Dist. Bagalkot 587301 PAN. AACAJ0614L Vs The ITO, Ward – 2, Bagalkot. Respondent Assessee by : Shri Ashok G. Mudnur, C. A. Revenue by : Smt. Padmameenakshi, JCIT (DR) Date of hearing : 03-12-2018 Date of pronouncement : 21-12-2018 O R D E R PER A. K. GARODIA, A.M.: This appeal is filed by the assessee and it is directed agains…

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

…the case of Bailhongal Urban Co-operative Bank Ltd. v. Joint CIT decided on August 28, 2013. But the decision of the Panaji Bench was based upon the decision of the Bombay High Court in Jalgaon District Central Co-operative Bank Ltd. v. Union of India [2004] 265 ITR 423 (Bom), wherein the Bombay High Court was concerned with Circular No. 9 of 2002, dated September, 11, 2002*, which made a distinction between the nominal members, associate members and sympathizer members. We are not concerned in this batch about the categorization of members. We are concerned about the distinction made between sub-clauses (a) and…

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

For Respondent: Shri. Sailendra Mamidi, PCIT

Section 194ASection 194A(3)Section 201

M/S. Nashik District Industrail & Mercantile Co-Op. Bank Ltd., Nashik vs. Income-Tax Officer

In the result, appeal of assessee is allowed

ITA 1967/PUN/2016[2012-13]Status: DisposedITAT Pune25 Sept 2018AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1967/Pun/2016 यििाारण वषा / Assessment Year : 2012-13 M/S. Nashik District Industrial & Mercantile Co-Op. Bank Ltd., 1, Shivkamal Appt., Canada Corner, अऩीऱाथी/Appellant Nashik – 422005 …. Pan: Aaaan1531A Vs. The Income Tax Officer, …. प्रत्यथी / Respondent Ward 1(2), Nashik

For Appellant: Shri Sanket JoshiFor Respondent: Shri Pankaj Garg

Section 143(3)Section 194ASection 194A(1)Section 194A(3)(v)Section 40

…)(ia) in the case of the assessee for this year. 3] The learned CIT(A) erred in not appreciating that the said issue is covered in favour of the assessee by the decision of Hon'ble Bombay H.C. in the case of 'The Jalgaon Dist. Central Co-op. Bank Ltd. v. Anr [265 ITR 423] wherein it has been held that the co-op, banks are not liable to deduct TDS u/s 194A in respect of interest paid to its members. 4] The learned CIT(A) further erred in not appreciating that the interest paid by co-operative banks to its members was made liable to deduction of TDS u/s 194A only w.e.f. 01.06.2015 vide amendment made to section 194…

The Commissioner of Income Tax vs. The Karnataka State Apex

Appeals are dismissed

ITA/505/2015HC Karnataka27 Jun 2016

Bench: JAYANT PATEL,B.SREENIVASE GOWDA

Section 194Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)Section 260

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 27th DAY OF JUNE, 2016 PRESENT THE HON'BLE MR. JUSTICE JAYANT PATEL AND THE HON’BLE MR. JUSTICE B.SREENIVASE GOWDA I.T.A. NO.505/2015 BETWEEN: 1. THE COMMISSIONER OF INCOME –TAX TDS NO.59, HMT BHAVAN, 4TH FLOOR BELLARY ROAD, GANGANAGAR BANGALORE – 560 032. 2. THE ASST. COMMISSIONER OF INCOME-TAX (TDS) CIRCLE-16(2) NO.59, HMT BHAVAN, 4TH FLOOR BELLARY ROAD, GANGANAGAR BANGALORE – 560 032. ... APPELLANTS (BY SRI.DILIP…

The Commissioner of Income Tax vs. The Karnataka State Apex

Appeals are dismissed

ITA/499/2015HC Karnataka27 Jun 2016

Bench: JAYANT PATEL,B.SREENIVASE GOWDA

Section 194Section 194A(3)(i)Section 194A(3)(v)Section 194A(3)(viia)Section 260

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 27th DAY OF JUNE, 2016 PRESENT THE HON'BLE MR. JUSTICE JAYANT PATEL AND THE HON’BLE MR. JUSTICE B.SREENIVASE GOWDA I.T.A. NO.499/2015 BETWEEN: 1. THE COMMISSIONER OF INCOME –TAX TDS., NO.59, HMT BHAVAN, 4TH FLOOR BELLARY ROAD, GANGANAGAR BANGALORE – 560 032. 2. THE ASST. COMMISSIONER OF INCOME-TAX (TDS) CIRCLE-16(2) NO.59, HMT BHAVAN, 4TH FLOOR BELLARY ROAD, GANGANAGAR BANGALORE – 560 032. ... APPELLANTS (BY SRI.DIL…