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“interest on securities”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(28B) / ITR Schedule OS681 judgments

The decision most relied on for interest on securities is South Indian Bank Ltd. v. CIT (438 ITR 1), cited in 508 judgments on BharatTax.

Leading authorities on interest on securities

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.
389 ITR 68 · 2016 · High Court
192
citing judgments

Income earned by a cooperative society from investing its surplus funds in short-term deposits and securities is not attributable to its core activities and therefore not eligible for deduction under Section 80P(2)(a)(i) of the Income-tax Act.

CIT v. Microlabs Ltd.
383 ITR 490 · 2016 · High Court
175
citing judgments

If an assessee possesses interest-free funds exceeding investments in tax-free securities, it is presumed that investments are made from these own funds, precluding disallowance of interest expenditure under Section 14A read with Rule 8D(2)(ii). Additionally, weighted deduction under Section 35(2AB) is computed on the gross expenditure incurred, not net expenditure after reducing income earned.

CIT v. Southern Eastern Employees Cooperative Credit Society Ltd.
390 ITR 524 · 2017 · High Court
170
citing judgments

Income from surplus funds invested in short-term deposits and securities by a cooperative credit society is not attributable to its activities and is therefore not eligible for exemption under section 80P(2)(a)(i) of the Income-tax Act.

CIT v. Vijaya Bank
187 ITR 541 · 1991 · Supreme Court
116
citing judgments

The 'broken period interest' paid on securities is considered part of the capital outlay for acquiring those securities and cannot be allowed as a revenue expenditure or business deduction. It must be capitalized.

American Express International Banking Corporation v. CIT
258 ITR 601 · 2002 · High Court
90
citing judgments

Interest paid by banks is allowable as a deduction in computing total income. The decision distinguished the Supreme Court's ruling in Vijaya Bank regarding the deductibility of such interest.

CIT v. Moni Kumar Subba
333 ITR 38 · 2011 · High Court
78
citing judgments

Notional interest on an interest-free security deposit cannot be considered as actual or deemed rent under Section 23(1) of the Act. For determining Annual Letting Value (ALV) under Section 23(1)(a), it must be in accordance with municipal laws, considering extraneous circumstances, but not exceeding the standard rent as per rent control legislation.

1. Bihar State Co-operative Bank Ltd. v. CIT
39 ITR 114 · 1960 · Supreme Court
76
citing judgments

Interest income earned by a co-operative bank from the investment of its surplus funds, including those statutorily required to be placed in approved securities, is attributable to its banking business and qualifies for deduction under Section 80P(2)(a)(i).

Judgments citing interest on securities

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

ITA 2379/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)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

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

ITA 2378/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)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

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

ITA 2377/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)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

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)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

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

ITA 2375/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)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

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

ITA 2374/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(1)Section 194A(3)(i)Section 194A(3)(v)Section 2(19)Section 201(1)

stated that section 194A(1) read with section 194A(3)(i) of the Act provides for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000/- for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However ... section 194A(1) read with section 194A(3)(1) of the Act which provide for deduction of tax on interest (other than interest on securities) over a specified threshold, i.e. Rs.10,000 for interest payment by banks and co-operative society engaged in banking business(co-operative bank). However

Pradipsinh Ghanshyamsinh Vaghela, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 325/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad11 Jul 2025AY 2018-19

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Pradeep Tulsian, A.RFor Respondent: Shri R P Rastogi, CIT. DR
Section 148Section 148ASection 250

that the assessee had sold immovable property during the year for a consideration of Rs.80 Lakhs and had also earned interest other than interest on securities amounting to Rs.67000/-. Accordingly, the case of the assessee was reopened and assessment framed ITA No.325/Ahd/2025 [Pradipsinh Ghanshyamsinh Vaghela vs. ITO] - 5 – making

The Orchid Heights Co.Op Housing Service Society Limited, Ahmedabad vs. ITO, Ward-3(3)(5), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 26/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad09 Jul 2025AY 2021-22

Bench: Dr. B.R.R. Kumar, Vice- & Ms Suchitra Kamblethe Orchid Heights Co-Op Income Tax Officer, Vs. Housing Service Society Ward-3(3)(5), Limited, Ahmedabad. Applewood Township, Nr. Shantipura Circle, Ahmedabad-382210.. [Pan :Aagat8437 K] (Appellant) .. (Respondent) Appellant By : Shri M J Ranpura, Ar Respondent By: Shri Suresh Chand Meena, Sr. Dr Date Of Hearing 03.07.2025 Date Of Pronouncement 09.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Is Filed By The Assessee Against The Appellate Order Dated 29.04.2024 Passed By The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, Relating To The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeals:

For Appellant: Shri M J Ranpura, ARFor Respondent: Shri Suresh Chand Meena, Sr. DR
Section 194ASection 194A(3)(v)Section 263Section 80PSection 80P(2)(d)Section 80P(4)

section 194A (3), it appears that it provides for exemption from deducting Tax Deducted at Source from the income on interest other than interest on securities as the cooperative societies other than cooperative banks meaning thereby that the cooperative banks are liable to deduct TDS from the interest other than ... interest on securities. Therefore it cannot be said that cooperative banks are excluded from the definition of cooperative societies by such an amendment. [Para 29]  Moreover, as reliance placed on the aforesaid decision for M/s. Mahak Creation Pvt. Ltd. Vs. ITO Asst. Year : 2018-19 - 4– applicability of section

Pokharna Educational Trust, Pune vs. CIT (Exemption), Pune

In the result, appeal of the assessee is dismissed

ITA 1244/PUN/2025[2020-21]Status: DisposedITAT Pune30 Jun 2025AY 2020-21
Section 10Section 10(23)Section 10(230)(iad)Section 12ASection 143(3)Section 263Section 57

computed after making the following deductions, namely :— (i) in the case of [dividends, other than dividends referred to in section 115-O], or interest on securities, any reasonable sum paid by way of commission or remuneration to a banker or any other person for the purpose of realising such dividend

Abhyudaya Co - Operative Bank Ltd, Dharavi Branch, Mumbai vs. Income Tax Officer (TDS)TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1811/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co - Operative Bank Ltd, Ganeshnagar Branch, Mumbai vs. Income Tax Officer (TDS), TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1810/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co - Operative Bank Ltd, Lalbaug Branch, Mumbai vs. Income Tax Officer (TDS) TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1809/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co - Operative Bank Ltd, Bhiwandi Branch, Mumbai vs. Income Tax Officer (TDS) TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1808/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co - Operative Bank Ltd Marve Link Road Branch, Mumbai vs. Income Tax Officer (TDS) TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1807/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co - Operative Bank Ltd Dahisar Branch, Mumbai vs. Income Tax Officer (TDS)TDS Ward 1(1)(1), Mumbai

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 1806/MUM/2025[2016-17]Status: DisposedITAT Mumbai30 Jun 2025AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 & Assessment Year: 2016-17 Abhyudaya Co-Operative Bank Ltd. Income Tax Officer (Tds) Dahisar Branch, Mumbai Tds Ward 1(1)(1), Mumbai Shop No.14 & 15, D Wing, Northern Vs. Room No. 413, 4Th Floor, Heights, Bldg 1, Shanti Ngr, Dongri, Cumballa Hill, Mtnl Tele S V Rd, Dahisar E- 400 068 Building, Pedder Road, Cumballa Hill, Mumbai- 400 026 Pan No. Aaaaa 0300 L Appellant Respondent Assessee By : Mr. Sharad A Vaze Revenue By : Mr. Aditya M. Rai, Cit-Dr

For Appellant: Mr. Sharad A VazeFor Respondent: Mr. Aditya M. Rai, CIT-DR
Section 145Section 194(3)(v)Section 194ASection 194A(3)Section 194A(3)(v)Section 201Section 201(1)Section 22Section 80P

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Sanand Sankardas, Mumbai vs. Income Tax Officer Int. Tax Ward 4(2)(1), Mumbai

ITA 1102/MUM/2025[2015-16]Status: DisposedITAT Mumbai27 Jun 2025AY 2015-16

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 133(6)Section 142(1)Section 144Section 144C(1)Section 144C(2)Section 147Section 148Section 148ASection 195Section 69

made investments to purchase immovable property valued at Rs.39,62,714/-, time deposit of Rs.30,36,720/-, TDS statement interest other than interest on securities of Rs.3,56,823/- and TDS statement, payment made to non-resident u/s 195 of Rs.2,28,760/-. From the e-filing portal

Bright Paints Pvt Ltd, Mumbai vs. Dy Commissioner of Income Tax - 12(1)(2), Mumbai

In the result, the ground no

ITA 6817/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Jun 2025AY 2014-15

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: Shri. Nitesh JoshiFor Respondent: Shri. Leyaqat Ali, SR. DR
Section 143(1)Section 143(2)Section 143(3)(ii)Section 14ASection 250Section 73

business of a company (other than a company whose gross total income consists mainly of income which is chargeable under the heads "Interest on securities", "Income from house property", "Capital gains" and "Income from other sources", or a company the principal business of which is the business of trading

Samir Narain Bhojwani, Mumbai vs. DCIT 4(2)(1), Mumbai

Appeal of the assessee is allowed for statistical purposes and the appeal of the revenue is dismissed

ITA 261/MUM/2025[2022-23]Status: DisposedITAT Mumbai26 Jun 2025AY 2022-23

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Shri Yogesh Thar & Chaitanya
Section 112Section 194CSection 250Section 37(1)Section 40Section 50

source in respect of payment relating to "interest". Section 193 of the IT Act deals with deduction of tax at source from "interest on securities" and section 194A deals with deduction of tax at source from "interest other than interest on securities. 14. It would be convenient at this stage ... Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Abhyudaya Co Operative Bank Ltd . Cbd Belapur Branch, Mumbai vs. Income Tax Officer (TDS) Ward 1(1)(1), Mumbai

In the result, all the 20 appeals of the assessee are allowed

ITA 2590/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Jun 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri Sharad A. Vaze, CAFor Respondent: Shri. Aditya M. Rai, Sr. DR
Section 194ASection 194A(3)(v)Section 201(1)Section 80PSection 80P(2)(d)

issue in hand, it is worthwhile to refer to the provisions contained in section 194A which is reproduce below: “Interest other than “Interest on securities”. 72194A. 73 (1) Any person, not being an individual or a Hindu undivided family, who is responsible for paying 74 to a resident any income ... interest other than income 75[by way of interest on securities], shall, at the time of credit of such income to the account of the payee 76 or at the time of payment thereof in cash or by issue of a cheque or draft or by any other mode, whichever

Abhyudaya Co Operative Bank Ltd, Jogeshwari East Branch, Mumbai vs. Income Tax Officer (TDS) Ward 1(1)(1), Mumbai

ITA 2589/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Jun 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawal

Section 194ASection 194A(1)Section 194A(3)(v)Section 201(1)Section 80PSection 80P(2)(d)

ITA No. 2571 to 2590/Mum/2025 Abhyudaya Co-operative Bank Ltd. AY 2016-17 IN THE INCOME TAX APPELLATE TRIBUNAL “A