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“assessee in default”

TDS / TCSSection 201Section 2011,654 judgments

The decision most relied on for assessee in default is Rashmikant Kundalia v. Union of India (54 Taxmann.com 200), cited in 702 judgments on BharatTax.

Leading authorities on assessee in default

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Hindustan Coca Cola Beverage Pvt. Ltd. v. CIT
293 ITR 226 · 2007 · Supreme Court
576
citing judgments

The deductor cannot be treated as an assessee-in-default under Section 201(1) if the deductee has already paid the tax or offered the impugned receipts in their return of income. However, interest under Section 201(1A) for delayed deposit of tax can still be levied up to the date of filing of the return of income by the deductee.

Earthmoving Equipment Service Corporation v. DCIT 22(2), Mumbai
84 Taxmann.com 51 · 2017 · ITAT
263
citing judgments

A penalty levied under Section 271(1)(c) for concealment of income or furnishing inaccurate particulars cannot be deleted merely due to technical defects in the penalty notice, such as not ticking the specific default, if the assessee understood the charges.

DIT v. GE Packaged Power Inc.
373 ITR 65 · 2015 · High Court
199
citing judgments

Interest under section 234B for default in payment of advance tax is not leviable when the entire income is subject to tax deduction at source under section 195, as no advance tax liability arises for the assessee in such circumstances.

247 ITR 305 (Guj) CIT v. Nestle India Ltd.
140 ITR 832 · 1983 · High Court
172
citing judgments

An employer is not in default under section 201 if they have made a bona fide estimate of employee income and deducted tax at source based on that estimate.

Jagaran Prakashan Ltd. v. DCIT
345 ITR 288 · 2012 · High Court
164
citing judgments

A deductor cannot be treated as an assessee in default for failure to deduct tax at source if the recipient has already paid the income tax directly. The onus is on the deductor to prove that the recipient has paid the tax.

CIT v. Kotak Securities Ltd.
340 ITR 333 · 2012 · High Court
161
citing judgments

A deductor's bonafide belief or reliance on a Tax Residency Certificate (TRC) can influence whether they are deemed an 'assessee in default' under Section 195 for failing to deduct tax at source on payments to non-residents. The decision clarifies the due diligence required when interpreting tax treaties and TRCs for TDS compliance.

CIT v. Idea Cellular Ltd.
325 ITR 148 · 2010 · High Court
155
citing judgments

Discounts offered to distributors under a tightly controlled relationship constitute commission and are subject to tax deduction at source under Section 194H of the Income-tax Act.

Judgments citing assessee in default

Jayant Security and Finance Ltd, Indore vs. ACIT Central-2, Bhopal

ITA 88/IND/2025[2014-15]Status: DisposedITAT Indore07 Jul 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 156Section 220(6)Section 221(1)Section 246ASection 253

pending. The Ld. AR next contended that u/s 220(6) of the Act the Ld. A.O has a discretion not to treat the assessee in default in respect of amount in dispute in the appeal, even though time for payment has expired. No notice in terms of proviso to Section

Jayant Security and Finance Ltd, Indore vs. ACIT Central-2, Bhopal

ITA 86/IND/2025[2010-11]Status: DisposedITAT Indore07 Jul 2025AY 2010-11

Bench: Shri B.M. Biyani & Shri Paresh M Joshi

Section 147Section 156Section 220Section 220(6)Section 221(1)Section 246ASection 253

pending. The Ld. AR next contended that u/s 220(6) of the Act the Ld. A.O has a discretion not to treat the assessee in default in respect of amount in dispute in the appeal, even though time for payment has expired. No notice in terms of proviso to Section

Surya Land Developers, Raipur vs. Income Tax Officer-1(4), Raipur

In the result, appeal of the Assessee is allowed

ITA 328/RPR/2025[2015-16]Status: DisposedITAT Raipur03 Jul 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Judicial Ember

For Appellant: Shri Vikaas S. Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr.-DR
Section 143(2)Section 143(3)Section 194CSection 201Section 40

respective payees as to the discharge of liabilities by the said payees in their respective individual assessments which renders the assessee not being assessee in default in terms of proviso to Section201 by virtue of which no disallowance u/s 40(a)(ia) is warranted, therefore, the Ld. AO's action

Mahayogi Vemana Souharda Pattina Sahakari Sangha, Bengaluru vs. Income Tax Officer, Ward-2(2), Bangalore

In the result, the appeal of the assessee is allowed

ITA 829/BANG/2025[2018-19]Status: DisposedITAT Bangalore02 Jul 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Ms. Sunaina Bhatia, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)
Section 194ASection 2(19)Section 201Section 201(1)Section 80P

year 2018- 19. 2. The only issue raised by the assessee is that the ld. CIT(A) erred in treating the assessee as ‘assessee in default’ on account of non Page 2 of 4 deduction of TDS on the payment of interest to members ... present case is a society and eligible for deduction u/s 80P of the Act therefore, the assessee cannot be treated as assessee in default on account of non-deduction of TDS on the payment of interest u/s 194A of the Act. Accordingly, we set aside the finding

The District Mining Officer, Bareilly vs. Income Tax Officer (TDS), Bareilly

ITA 246/LKW/2018[2008-09]Status: DisposedITAT Lucknow30 Jun 2025AY 2008-09

Bench: Sh. Sudhanshu Srivastava & Sh. Nikhil Choudhary

For Appellant: Revenue byFor Respondent: Date of hearing
Section 133ASection 206CSection 250

Rs.6,93,961.5/- inclusive of interest. The assessee was therefore informed that he was being deemed to be an assessee in default, for the aforesaid amount and accordingly a total demand to this extent was raised. 4. Aggrieved with the said order, the assessee went in appeal

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

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

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect of alleged non-deduction of tax from interest paid to co-operative societies u/s 194A of the Income ... Assessing Officer was not satisfied with the submission of the assessee and accordingly he treated the assessee has assessee-in-default in respect of interest payment amounting to Rs.6,16,733/-, a list of which has been reproduced by the assessing officer in paragraph 7 of the impugned order

M/S. Sanklecha Constructions, Nashik vs. The Income Tax Officer, ITO(TDS), Nashik

In the result, appeal of the assessee is dismissed

ITA 1265/PUN/2025[2015-16]Status: DisposedITAT Pune27 Jun 2025AY 2015-16

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकरअपीलसं. / Ita No.1265/Pun/2025 िनधा"रणवष" / Assessment Year: 2015-16 M/S.Sanklecha Constructions, V The Income Tax Officer, 11, Op. Of Kalika Park, Agra S. Ito(Tds), Nashik. Road, District Nashik, Nashik – 422002. Maharashtra. Pan: Aaffs1432H Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte– Ar Revenue By Shri Akhilesh Srivastva– Addl.Cit(Dr) Date Of Hearing 18/06/2025 Date Of Pronouncement 27/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Addl./Joint Commissioner Of Income Tax(Appeal)-1, Hyderabad Passed Under Section 250 Of The Income Tax Act, 1961 For A.Y.2015-16, Dated 28.03.2025 Emanating From Order U/S.201 Of The Income Tax Act, Dated 31.03.2022. The Assessee Has Raised Following Grounds Of Appeal :

Section 156Section 201Section 201(1)Section 250

under this Act, then, such person, shall, without prejudice to any other consequences which he may incur, be deemed to be an assessee in default in respect of such tax: Provided that any person, including the principal officer of a company, who fails to deduct the whole or any part ... paid to a resident or on the sum credited to the account of a resident shall not be deemed to be an assessee in default in respect of such tax if such resident— (i) has furnished his return of income under section 139; (ii) has taken into account such

State Bank of India, Chennai vs. ACIT TDS, Chennai

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

ITA 1465/CHNY/2024[2015-16]Status: DisposedITAT Chennai27 Jun 2025AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1465/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 State Bank Of India Vs. The Assistant Commissioner Of Industrial Finance Branch, Income Tax, 103, Mount Road, Chennai 600 002. Tds Circle 3(1), [Tan:Ches02510E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. G. Vardini Karthik, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri N. Madan Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.04.2025 घोषणा की तारीख /Date Of Pronouncement : 27.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.03.2024 Passed By The Addl/Jcit(1)-1, Coimbatore For The Assessment Year 2015-16. 2. The Assessee Raised 17 Grounds Of Appeal, Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Order Passed Under Section 201/201(1A) Of The Income Tax Act, 1961 [“Act” In Short] In The Facts & Circumstances Of The Case.

For Appellant: Ms. G. Vardini Karthik, Advocate (virtual)For Respondent: Shri N. Madan Kumar, JCIT
Section 10(5)Section 192BSection 201

Civil Appeal No. 8181 of 2022) dated 04.11.2022 confirmed the view of the Assessing Officer’s stand therein, treating the employer i.e., the assessee in default for non deducting tax source while realizing payments to its employee as leave fare concession on foreign travel. Accordingly, the Assessing Officer determined ... dated 4th Nov, 2022 has dismissed the assessee's appeal and confirmed AD's stand as treating the employer as assessee in default for not deducting tax at source while releasing payments to its employees as Leave travel Concession (LFC)(on foreign travel). The relevant part of the decision

Aakash Purshottambhai Vaghela, Vadodara vs. The ITO, TDS-1, Vadodara

In the result, the appeal of the assessee is partly allowed

ITA 1064/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad26 Jun 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 194ISection 194JSection 201(1)

failure to pay tax at source (TDS) under Section 194IA and 194J of the Act. The assessee was treated as “assessee in default” under Section 201(1)/201(1A) of the Act and total tax liability of Rs.3,19,728/- was worked out as under: - S.No. Name of the Nature ... under Section 194J of the Act in respect of audit fee payment of Rs.39,000/-, the assessee was rightly treated as “assessee in default” under Section 201(1) of the Act. As regards interest u/s 201(1A) of the Act, the AO is directed to verify the payment

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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s. 194A of the Income Tax Act 1961. 2. Without ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default’ for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since

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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s.194A of the Income Tax Act 1961. 2. Without prejudice ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default' for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since

Abhyudaya Co-Operative Bank Ltd Worli Branch, Mumbai vs. ITO TDS, Ward 1(1)(1), Mumbai

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

ITA 2588/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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s. 194A of the Income Tax Act 1961. 2. Without ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default’ for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since

Abhyudaya Co Operative Bank Ltd . Ghatkopar Branch, Mumbai vs. Income Tax Officer (TDS)Ward1(1)(1), Mumbai

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

ITA 2587/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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s. 194A of the Income Tax Act 1961. 2. Without ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default’ for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since

Abhyudaya Co-Operative Bank Ltd Sewri Branch, Mumbai vs. ITO (TDS) Ward 1(1)(1), Mumbai

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

ITA 2586/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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s. 194A of the Income Tax Act 1961. 2. Without ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default’ for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since

Abhyudaya Co-Operative Bank Ltd Divale Cbd Branch, Mumbai vs. ITO (TDS) Ward 1(1)(1), Mumbai

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

ITA 2585/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)

under: “1. In the facts and circumstances of the case, the lower authorities have erred in law as well as in fact treating assessee in default in respect alleged non- deduction of tax from interest paid to co-operative societies u/s. 194A of the Income Tax Act 1961. 2. Without ... which are identical in nature expect for various in the quantum of tax liability imposed on the assessee by holding the assessee as ‘assessee in default’ for non-deduction of tax at source from payment of interest to various co-operative societies as per Section 194A of the Act. Since