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“section 194N”

TDS / TCSSection 194NSection 194N13 judgments

The decision most relied on for section 194N is Allied Motors (P) Ltd. v. CIT (224 ITR 677), cited in 398 judgments on BharatTax.

Leading authorities on section 194N

Allied Motors (P) Ltd. v. CIT
224 ITR 677 · 1997 · Supreme Court
398
citing judgments

Amendments to the Income-tax Act that are curative, clarificatory, or beneficial in nature apply retrospectively from the date the original statutory provision was introduced, even if not explicitly stated.

COMMISSIONER OF INCOME TAX v. VASISTH CHAY VYAAR LIMITED
90 Taxmann.com 365 · 2018 · Supreme Court
15
citing judgments

Interest income on Non-Performing Assets (NPA) need not be recognized on an accrual basis and the provisions of Section 145 of the Income Tax Act do not play a role in such income recognition. Furthermore, if interest does not result in any income, there can be no levy of tax.

Judgments citing section 194N

Sidhesh Mohan Raikar, Nashik vs. Deputy Director of Income Tax, Centralized Processing Centre, Banglore

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

ITA 294/PUN/2025[2023-24]Status: DisposedITAT Pune11 Dec 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.294/Pun/2025 Assessment Year : 2023-24

For Appellant: Shri Devendra JainFor Respondent: Shri Pramod Shahkar
Section 143(1)Section 154Section 199Section 5A

income is assessable to tax. [(3A) Notwithstanding anything contained in sub-rule (1), sub-rule (2) or sub-rule (3), for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government

Surbhi Anand, South Delhi vs. ACIT, Circle-1(1)(1), Agra

In the result, the appeal of the assessee is allowed

ITA 258/AGR/2025[2023-24]Status: DisposedITAT Agra09 Oct 2025AY 2023-24

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh[Assessment Year: 2023-24] Surbhi Anand, Acit, C-155, Basement, Lajpat Circle-1(1)(1), Nagar-2, South Delhi, Vs Aayakar Bhawan, Sanjay Place, Delhi-110024 Agra, Uttar Pradesh-282002 Pan-Acypa6580B Appellant Respondent Appellant By Shri Sahib P. Satsangi, Ca Respondent By Shri Anil Kumar, Sr. Dr Date Of Hearing 15.07.2025 Date Of Pronouncement 09.10.2025 Order, Per Brajesh Kumar Singh, Am

Section 143Section 143(1)Section 145Section 154Section 193

assessable to tax. 41[(3A) Notwithstanding anything contained in sub-rule (1), sub- rule (2) or sub-rule (3), for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government account

Dulhe Ram Meena, Jaipur vs. DCIT Circle 1, Jaipur

Appeal is allowed

ITA 72/JPR/2025[2023-24]Status: DisposedITAT Jaipur25 Sept 2025AY 2023-24

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Rohan Sogani, CAFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR
Section 143(1)Section 199Section 37B

income is assessable to tax. "[(3A) Notwithstanding anything contained in sub-rule (1), sub-rule (2) or sub-rule 31 for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government

The District Central Co-Op. Bank Ltd., Tirunelveli vs. ITO, TDS Ward, Tirunelveli

In the result, the appeal of the assessee is partly allowed with the above directions

ITA 1113/CHNY/2025[2020-21]Status: DisposedITAT Chennai11 Sept 2025AY 2020-21

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ Ita No.1113/Chny/2025 िनधा:रण वष: /Assessment Year: 2020-21

For Appellant: Shri Y.Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 194NSection 201(1)Section 40

demand of Rs.2,81,08,896/- (later revised to Rs.4,08,85,687/-) was raised on account of non-deduction of TDS under section 194N. The District Central Co-op. Bank Ltd. :- 2 -: 2. The assessee has raised the following legal grounds of appeal: “1. That the Order ... accounts with the appellant. Due to various constraints beyond the The District Central Co-op. Bank Ltd. :- 3 -: control of the assessee, TDS under section 194N was not deducted on certain cash withdrawals made by the PACBs, particularly during the initial phase post introduction of the said section, which came

M/S. the Coimbatore District Central Co-Op. Bank Ltd., Coimbatore vs. ITO, TDS Ward-2, Coimbatore

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

ITA 1004/CHNY/2025[2020-21]Status: DisposedITAT Chennai12 Aug 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1004/Chny/2025 िनधा9रण वष9 /Assessment Year: 2020-21 M/S. Coimbatore District Central The Income Tax Officer, Co-Op. Bank Ltd., Vs. Tds Ward-2 (I/C), 80, State Bank Road, Coimbatore. Coimbatore – 641 018. [Pan: Aabat 3010F]

For Appellant: Shri T.Vasudevan, Advocate
Section 133ASection 194NSection 201Section 201(1)

respect of cash payments exceeding one crore rupees during the previous year as per The Coimbatore District Central Co-op. Bank Ltd. :- 3 -: section 194N of the Act, as the cooperative societies withdrew cash only for onward distribution towards various Government schemes such as the Pongal gift hampers ... deducted TDS in respect of certain PACCS which had withdrawn cash of more than Rs.1 Cr. during the financial year as required by section 194N of the Act. The A.O, therefore, treated the assessee as being in default in respect of 2% of such cash withdrawal exceeding Rs 1 crore

Tirumala Estates, Hyderabad vs. Income Tax Officer, Ward-4(1), Hyderabad

ITA 143/HYD/2024[2022-23]Status: DisposedITAT Hyderabad30 Jul 2025AY 2022-23

Bench: Us:

Section 143(1)Section 194I

income is assessable to tax. (3A) [ Notwithstanding anything contained in sub-rule (1), sub-rule (2) or sub-rule (3), for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government

The Thoothukudi District Central Co-Op Bank Ltd., Tuticorin vs. ITO, TDS Ward, Tirunelveli

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

ITA 1337/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Jul 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.1337/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 V. The Thoothukudi District – The Ito, Central Co-Op. Bank Ltd., Tds Ward, 109/5, Ettayapuram Road, Tirunelveli. Polpettai, Tuticorin Central Bus Stand S.O., Indra Nagar, Tuticorin-628 002. [Pan: Aaatt 3499 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr.S. Girish Kumar, Advocate : ""यथ" क" ओर से /Respondent By Mr. Gauthami Manivasagam, Jcit : सुनवाईक"तारीख/Date Of Hearing 15.07.2025 : घोषणाक"तारीख /Date Of Pronouncement 21.07.2025

For Appellant: Mr.S. Girish Kumar, Advocate
Section 133ASection 194NSection 201

excess of Rs.1 crore during the previous year 2019-20 was called for to ascertain whether the assessee has complied with the provisions of Section 194N of the Act. A show cause notice was issued. The AO has not considered the facts detailed in the reply of show cause notice

Shreenath Mhaskoba Credit Co-Op. Society Ltd., Pune vs. The PCIT, Pune-4, Pune

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

ITA 488/PUN/2025[2020-21]Status: DisposedITAT Pune17 Jun 2025AY 2020-21

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2020-21

For Appellant: Shri Sanjay SuryawanshiFor Respondent: Shri Vishwas S. Mundhe
Section 143(2)Section 143(3)Section 194NSection 263Section 56Section 80P(2)(a)Section 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

M/S Baba Kanwar Ram Fruit Co., Alwar vs. ITO, Ward-1(2), Alwar

ITA 375/JPR/2025[2020-21]Status: DisposedITAT Jaipur26 May 2025AY 2020-21

Bench: Nfac, Feeling Aggrieved By The Assessment Order Dated 05.09.2022, Passed By The Assessing Officer. Vide Impugned Order, Learned Cit(A) Dismissed The Appeal Filed By The Assessee & Consequently Upheld The Addition Made. 2. As Regards The Addition, Vide Impugned Order Dated 05.09.2022, The Assessing Officer Assessed Total Income Of The Assessee By Making Addition As Depicted In The Table Below:- Sl. Description Amount (In Inr) No. 1. Income As Per Return Of Income Filed 19,46,350/- 2. Income As Computed U/S 143(1)(A) 19,46,350/- 3. Add: Disallowance Of The Discount 49,16,194/- Paid 4. Total Income/Loss Determined As Per 68,62,544/- The Above Proposal

For Appellant: Sh. P.C. Parwal, C.AFor Respondent: Sh. Gorav Avasthi, JCIT
Section 142(1)Section 143(1)(a)Section 143(2)Section 194NSection 250

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B-BENCH” JAIPUR Jh jkBkSM+ deys

Hcc Cp Pl Jv, Hyderabad vs. Income Tax Officer, Ward-14(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 1005/HYD/2024[2018-19]Status: DisposedITAT Hyderabad24 Feb 2025AY 2018-19

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2018-19 Hcc Cp Pl Jv, Vs. The Income Tax Officer, Ward –14(1), Hyderabad. Hyderabad. Pan : Aaaah5541G. (Assessee) (Respondent) Assessee By: Shri Gvn Hari, Advocate (Appeared Through Hybrid Mode) Revenue By: Shri Srinath Sadanala, Sr.Dr Date Of Hearing: 06.02.2025 Date Of Pronouncement: 24.02.2025

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Shri Srinath Sadanala, Sr.DR
Section 194CSection 199Section 238Section 238(1)

income is assessable to tax. [(3A) Notwithstanding anything contained in sub-rule (1), sub-rule (2) or sub-rule (3), for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government

Space Developers, Ahmedabad vs. The ITO, Ward-1(1)(3), Ahmedabad

In the result, the appeal of the assessee stands dismissed

ITA 1737/AHD/2024[2023-24]Status: DisposedITAT Ahmedabad19 Nov 2024AY 2023-24

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2023-24 Space Developers The Ito 501, Gurukrupa Avenue, Vs Ward-1(1)(3) Nr. Manekbaug Hall Ahmedabad Ambawadi Ahmedabad – 380 015 (Gujarat) Pan: Absfs 0313 F (Applicant) (Responent) : Assessee By Shri Sakar Sharma, Ar Revenue By : Shri Ketan Gajjar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 11/11/2024 घोषणा की तारीख /Date Of Pronouncement: 19/11/2024 आदेश/O R D E R

For Respondent: Shri Ketan Gajjar, Sr.DR
Section 143(1)Section 199Section 250

assessable to tax. 1[(3A) Notwithstanding anything contained in sub-rule (1), sub-rule (2) or sub-rule (3), for the purposes of section 194N, credit for tax deducted at source shall be given to the person from whose account tax is deducted and paid to the Central Government account

DCIT, Central Circle - 7(1), Mumbai vs. Rare Enterprises, Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 1442/MUM/2024[2018-19]Status: HeardITAT Mumbai27 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawal

Section 143(3)

income of an assessee, shall not be deemed to be income received: Provided further that the sum deducted in accordance with the provisions of section 194N for the purpose of computing the income of an assessee, shall not be deemed to be income received." 6.2. Accordingly, in the present

Deepak Ramlal Wadhawan, Mumbai vs. Assistant Commissioner of Income Tax-27(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1251/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Sept 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawalassessment Year: 2014-15

For Appellant: NoneFor Respondent: Smt. Mahita Nair, Sr. DR
Section 143(3)Section 57

income of an assessee, shall not be deemed to be income received: Provided further that the sum deducted in accordance with the provisions of section 194N for the purpose of computing the income of an assessee, shall not be deemed to be income received.” 6.1. From the above, we note