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18 results for “TDS”+ Section 194A(3)(iii)clear

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Mumbai262Delhi115Bangalore108Chandigarh89Chennai72Kolkata38Karnataka31Hyderabad25Jaipur23Pune21Ahmedabad18Nagpur16Raipur11Visakhapatnam9SC7Telangana6Cuttack5Rajkot5Jabalpur5Jodhpur4Kerala4Panaji4Allahabad3Ranchi3Indore3Guwahati2J&K2Surat2Amritsar1Cochin1Lucknow1Patna1

Key Topics

Section 80P(2)(d)45Section 80P24Section 4020Section 143(3)18Deduction12Disallowance12Addition to Income11Section 2637TDS7Section 194A

THE ASSTT. COMMISSIONER OF INCOME TAX, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P. INFRASTRUCTURE LTD.),, AHMEDABAD

ITA 421/AHD/2017[2008-0]Status: DisposedITAT Ahmedabad07 Feb 2022

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

For Appellant: Smt. Nupur Shah, ARFor Respondent: Shri Mohd. Usman, CIT DR & Shri
Section 194Section 194ASection 2(22)(e)Section 201(1)

194A on loan of Rs. 19,56,37,008/- ITA No.220/Ahd/2015 & CO No. 24/Ahd/2016 ITA No. 421/Ahd/2017 & C.O. No. 54/Ahd/2017 Asst.Year –2007-08 & 2008-09 advanced by the assessee company to the other group companies has been mainly challenged before us. 3. The brief facts leading to the case is this that the assessee had given inter-corporate deposit

THE DCIT, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P.INFRASTRUCTURE LTD., AHMEDABAD

5
Section 574
Section 2504
ITA 220/AHD/2015[2007-08]Status: DisposedITAT Ahmedabad07 Feb 2022AY 2007-08

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

For Appellant: Smt. Nupur Shah, ARFor Respondent: Shri Mohd. Usman, CIT DR & Shri
Section 194Section 194ASection 2(22)(e)Section 201(1)

194A on loan of Rs. 19,56,37,008/- ITA No.220/Ahd/2015 & CO No. 24/Ahd/2016 ITA No. 421/Ahd/2017 & C.O. No. 54/Ahd/2017 Asst.Year –2007-08 & 2008-09 advanced by the assessee company to the other group companies has been mainly challenged before us. 3. The brief facts leading to the case is this that the assessee had given inter-corporate deposit

THE BAVLA GROUP SEVA SAHAKAR MANDALI LTD,BAVLA, AHMEDABAD vs. ITO, WARD 3(2)(5), AHMEDABAD, AMBAWADI, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 2165/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad20 Feb 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri P D Shah, A.RFor Respondent: Shri Ravindra, Sr. DR
Section 194ASection 194A(3)(v)Section 80PSection 80P(2)(d)

194A (3) of the Act, it appears that it provides for exemption from deducting Tax Deducted at Source ['TDS' for short] 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

SOHAMNAGAR CO-OP HOUSING SOCIETY VIBHAG-III,AHMEDABAD vs. THE ITO, WARD-3(3)(5), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 2147/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad20 Feb 2025AY 2020-21

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Samir Vora, A.RFor Respondent: Shri Ravindra, Sr. DR
Section 194A(3)(v)Section 250Section 80PSection 80P(2)(d)

194A (3) of the Act, it appears that it provides for exemption from deducting Tax Deducted at Source ['TDS' for short] 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

DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR vs. THE SARDAR PAEL COOPERATIVE CREDIT SOCIETY LIMITED, GANDHINAGAR

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

ITA 1122/AHD/2023[2020-21]Status: DisposedITAT Ahmedabad29 Nov 2024AY 2020-21

Bench: The Final Hearing Of The Appeal.

Section 143(3)Section 19Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(d)

194A (3) of the Act, it appears that it provides for exemption from deducting Tax Deducted at Source [‘TDS’ for short] 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

DHANLAXMI CREDIT CO. OP. SOCIETY LTD.,MEHSANA vs. THE ITO, WARD-2, PATAN

In the result, Ground Number 3 of the appeal of the assessee is allowed

ITA 1870/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad11 Feb 2025AY 2017-18

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri M. K. Patel, A.RFor Respondent: Shri V K Mangla, Sr. DR
Section 263Section 80PSection 80P(2)(c)Section 80P(2)(d)

194A (3) of the Act, it appears that it provides for exemption from deducting Tax Deducted at Source ['TDS' for short] 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

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. THE GUJARAT STATE CO. OP. HOUSING FINANCE CORPORATION LTD, AHMEDABAD

The appeals of the Revenue are hereby dismissed

ITA 924/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Aarsi Prasad, CIT-DRFor Respondent: Shri Pritesh Shah, CA
Section 143(3)Section 263Section 80PSection 80P(2)(d)

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

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. THE GUJARAT STATE CO. OP. HOUSING FINANCE CORPORATION LTD, AHMEDABAD

The appeals of the Revenue are hereby dismissed

ITA 925/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Aarsi Prasad, CIT-DRFor Respondent: Shri Pritesh Shah, CA
Section 143(3)Section 263Section 80PSection 80P(2)(d)

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

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. THE GUJARAT STATE CO. OP. HOUSING FINANCE CORPORATION LTD, AHMEDABAD

The appeals of the Revenue are hereby dismissed

ITA 923/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad05 Dec 2024AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

For Appellant: Shri Aarsi Prasad, CIT-DRFor Respondent: Shri Pritesh Shah, CA
Section 143(3)Section 263Section 80PSection 80P(2)(d)

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

SHREE SARVODAYA SAHAKARI MANDALI LTD.,VADODARA vs. NFAC, DELHI PRESENT JURISDICTION THE DY.CIT, CIRCLE-2(1)(1), VADODARA

In the result, both the appeals of the assessee are allowed

ITA 1349/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2017-18

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Viranch Modi, A.RFor Respondent: Ms. Ketaki Desai, Sr. DR
Section 143(3)Section 147Section 80Section 80PSection 80P(2)(d)

194A (3), it appears that it provides for exemption from deducting Tax Deducted at Source from the income on interest other than interest on ITA No.1348 & 1349/Ahd/2024 Asst.Years 2016-17 & 2017-18 - 6– 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

SHREE SARVODAYA SAHAKARI MANDALI LTD.,VADODARA vs. NFAC, DELHI PRESENT JURISDICTION THE DY. CIT, CICLE-2(1)(1), VADODARA

In the result, both the appeals of the assessee are allowed

ITA 1348/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jan 2025AY 2016-17

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Viranch Modi, A.RFor Respondent: Ms. Ketaki Desai, Sr. DR
Section 143(3)Section 147Section 80Section 80PSection 80P(2)(d)

194A (3), it appears that it provides for exemption from deducting Tax Deducted at Source from the income on interest other than interest on ITA No.1348 & 1349/Ahd/2024 Asst.Years 2016-17 & 2017-18 - 6– 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

DUSHYANTSINH YADVENDRASINH CHUDASAMA,VADODARA vs. DY.COMM. OF INCOME TAX, CIRCLE-1(2), VADODARA

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

ITA 353/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad19 Mar 2025AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Kinjal Shah, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 143(3)Section 40Section 43BSection 68Section 69

iii) of the Act rather than under Section 57 of the Act. The AO also noted that Form 15G/15H, which could have exempted the assessee from TDS deduction, had not been furnished. Further, since no TDS had been deducted on these ITA Nos.353 & 354/Ahd/2022 Dushyantsinh Yadvendrasinh Chudasama vs. DCIT Asst. Years : 2014-15 & 2015-16 payments as required under Section

DUSHYANTSINH YADVENDRASINH CHUDASAMA,VADODARA vs. INCOME TAX OFFICER, WARD-1(2)(4), VADODARA

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

ITA 354/AHD/2022[2015-16]Status: DisposedITAT Ahmedabad19 Mar 2025AY 2015-16

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Kinjal Shah, ARFor Respondent: Shri Rignesh Das, Sr.DR
Section 143(3)Section 40Section 43BSection 68Section 69

iii) of the Act rather than under Section 57 of the Act. The AO also noted that Form 15G/15H, which could have exempted the assessee from TDS deduction, had not been furnished. Further, since no TDS had been deducted on these ITA Nos.353 & 354/Ahd/2022 Dushyantsinh Yadvendrasinh Chudasama vs. DCIT Asst. Years : 2014-15 & 2015-16 payments as required under Section

M/S. BAJAJ FOODS LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-1(2),, AHMEDABAD

Appeal of the assessee is allowed for statistical purposes

ITA 1647/AHD/2012[2009-10]Status: DisposedITAT Ahmedabad25 Feb 2022AY 2009-10
For Appellant: Shri Parimalsigh Parmar, A.RFor Respondent: Shri Dinesh Singh, Sr. D.R
Section 250(6)Section 36Section 36(1)(iii)

iii) is called for. In the light of aforesaid facts and circumstances, we observe that the Assessing officer and the ld. CIT (A) has not given categorical finding on the following issues. (i) Whether assessee had sufficient interest free funds to cover advances given to its associate concerns and no interest bearing fund was advanced to its associate concerns

MUKESH CHHOTELAL GUPTA,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is treated as allowed for statistical purposes

ITA 797/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad12 Aug 2025AY 2018-19

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Shri Mukesh Chhotelal Gupta The Dcit, Cir.(1)(1) Gupta Nivas Vs. Ahmedabad. Chandkheda Sabarmati Ahmedabad 380 015. Pan : Ablpg 9729 N (Applicant) (Responent) : Assessee By Shri S.N. Divatia & Shri Samir Vora, Ar : Shri Ashok Kumar Suthar, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 31/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025 आदेश आदेश/O R D E R आदेश आदेश

Section 142(1)Section 143(2)Section 143(3)Section 145(1)Section 194ASection 57

194A. The assessee’s computation under the head “Income from other sources” disclosed interest from savings bank Rs.15,475/-. commission income Rs.3,74,723/-, interest on fixed deposits and from parties Rs.51,17,989/- aggregating to Rs.55,08,187/-. Against the said total, the assessee claimed interest expense of Rs.51,17,989/- and commission related expenses of Rs.6,751, returning

NIMBESHWAR GUDADRAM DESAI,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1) (PREVIOUSLY CIRCLE-3(3)), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1436/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad01 Oct 2025AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 143(3)Section 194ASection 36(1)Section 40

194A. In response to notice, the assessee admitted that TDS had not been deducted on such payments, on the ground that he was under the belief that TDS was not applicable in the case of NBFCs. The Assessing Officer held that the failure to deduct tax attracted disallowance of 30% of the expenditure under section

CHANDRAKANT GORDHANBHAI PATEL HUF ,DABHOI vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-1(3), VADODARA, VADODARA

In the result, appeal of the assessee in ITA no

ITA 485/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2012-13

Bench: The Final Hearing Of This Appeal Petition…”

For Appellant: None(Written Submission filed by the assessee)For Respondent: Shri Sanjay Jain, Sr. D.R
Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250

TDS refund received by him, has been given to them equally, He further argued that there are various judicial decisions of High court and Supreme Court that interest awarded by the Court orders in acquisition of land is part of award or compensation, so it is capital receipts and not revenue receipts. Hence, not taxed here. He also cited

ISPATAM METALS,AHMEDABAD vs. THE ITO, WAD-5(3)(1), AHMEDABAD

In the result all the grounds raised on merits of the addition made are dismissed

ITA 292/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad29 Oct 2025AY 2018-19

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year: 2018-19

For Appellant: Shri S.N. DivetiaFor Respondent: Shri Rignesh Das, CIT-D.R
Section 250

3. As is evident from perusal of the grounds as above, the assessee has agitated the confirmation by the CIT(A) of the addition made by the Assessing Officer on account of capital introduced in assessee firm, the source of which remained unexplained, amounting to Rs. 2,92,98,928/-; unsecured loans taken by the assessee source of which remained