Kerala Finance Corporation v. CIT

210 ITR 129Supreme Court of India1994#1808 most cited

What is Kerala Finance Corporation v. CIT authority for?

CBDT circulars, instructions, or directions issued under Section 119 cannot override or detract from the provisions of the Income-tax Act, as a delegated authority lacks the power to amend law enacted by Parliament.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

Kerala Finance Corporation v. CIT · 210 ITR 129 · CBDT circulars · Section 119 · circulars cannot override Act · binding nature of instructions · delegated legislation · Section 194A · Section 201 · statutory provisions · tax administration

Sections most often in play

Section 194ASection 201(1A)Section 201(1)Section 250Section 201Section 194A(3)(v)Section 115BBESection 153B

Issues it is cited on

section 194a(v)section 194(3)(viia)(b)section 5(1)(cc)section 80p(i)section 194a(3)(viia)(b)section 194a(3)(viia)(a)section 194a(3)(i)(b)section 194(3)(v)section 194a(3)(i)section 132(5)section 132(2)section 194a(1)

Judgments citing Kerala Finance Corporation v. CIT

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

ITA 6440/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20
Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6436/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6433/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…nt. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6432/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 ==End of OCR for page 31== ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6431/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6430/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6422/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZENCREDIT CO-OPERTIVE BANK LIMITED (COLABA BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6420/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6419/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6418/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6417/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6416/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6414/MUM/2025[2017-18]Status: DisposedITAT Mumbai19 Jan 2026AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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

ITA 6409/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD,MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6408/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD,MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6406/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (KALINA BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6400/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (VIKHROLI BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6396/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…llant. 16.2 At this stage, it may be mentioned that the Circular, Instruction, Order or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (VAKOLA BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6393/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

CITIZEN CREDIT CO-OPERATIVE BANK LTD (AMBOLI BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

ITA 6389/MUM/2025[2019-20]Status: DisposedITAT Mumbai19 Jan 2026AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

Section 194ASection 194A(3)(v)Section 2(19)Section 201Section 201(1)Section 250

…or Direction issued by the CBDT cannot override or detract from the provisions of the Act, as held by the Hon'ble Supreme Court in case of Kerala Finance 31 ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. Corporation vs. CIT, 210 ITR 129 (SC). The Hon'ble SC held that “Such an order, instruction on direction cannot override the provisions of the Act; that would be destructive of all known principles of law as the same would really amount to giving power to a delegated authority to even amend the provision of law enacted by the Parliament. Such a contention cannot seriously be eve…

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