M/S THE RADDI SAHAKARA BANK NIYAMITHA,DHARWAD vs. INCOME TAX OFFICER,, HUBLI

In the result, the appeals by the assessee are allowed, while the stay petitions are dismissed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

TDS under section 194A. ITA Nos.368 & 369/Bang/2015 & SP Nos.51 & 52/Bang/2015 Page 15 of 17 3. A question has also been raised as to whether normal members, associate members and sympathizer members are also covered by the exemption under section 194A(3)(v). It is hereby clarified that the exemption is available only to such members who have joined in application

ITO, BANGALORE vs. THE BHARAT CO-OPERATIVE BANK (MUMBAI) LTD.,, BANGALORE

In the result, the appeals by the Revenue and CO by the assessee are dismissed

Bench: Smt. Asha Vijayaraghavan & Shri Jason P. Boaz

TDS under section 194A. 3. A question has also been raised as to whether normal members, associate members and sympathizer members are also covered by the exemption under section 194A(3)(v). It is hereby clarified that the exemption is available only to such members who have joined in application for the registration of the co-operative society and those

DCIT, BANGALORE vs. M/S CITIZEN CO-OP BANK LTD.,, BANGALORE

In the result, appeal of the Revenue is dismissed

Bench: Shri. N. V. Vasudevan & Shri. Abraham P. George

TDS under section 194A. 3. A question has also been raised as to whether normal members, associate members and sympathizer members are also covered by the exemption under section 194A(3)(v). It is hereby clarified that the exemption is available only to such members who have joined in application for the registration of the co-operative society and those

STATE BANK OF INDIA,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 16(2), BANGALORE

In the result, the appeal is allowed

Bench: Shri N.V. Vasudevan & Shri D.S. Sunder Singhassessment Year: 2013-14

TDS) treating the assessee as one in default u/s.201(1) and levying interest u/s.201(1A) of the Act.” Page 11 of 11 7. Since this Tribunal has already taken a view that the person to whom interest was paid was falling within the ambit of section 194A(3)(f

CANARA BANK (ERSTWHILE SYNDICATE BANK),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

TDS is not to be deducted. It is very relevant to note that at the time of Acquisition Act was enacted, Central Government had issued a Notification No. SO 710 dated 16/02/1970 [1970] [Reported in 75 ITR (Stat) 106] which reads as under:- 58. Income-tax Act, 1961: Notification under sec. 194A(3)(iii)(f) Notification

ASSISTANT COMMISSIONER OF INCOME TAX, BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

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

TDS is not to be deducted. It is very relevant to\nnote that at the time of Acquisition Act was enacted, Central\n\nGovernment had issued a Notification No. SO 710 dated 16/02/1970\n[1970] [Reported in 75 ITR (Stat) 106] which reads as under:-\n58. Income-tax Act, 1961: Notification under sec. 194A(3)(iii)(f)\nNotification

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

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

TDS is not to be deducted. It is very relevant to\nnote that at the time of Acquisition Act was enacted, Central\nGovernment had issued a Notification No. SO 710 dated 16/02/1970\n[1970] [Reported in 75 ITR (Stat) 106] which reads as under:-\n58. Income-tax Act, 1961: Notification under sec. 194A(3)(iii)(f)\nNotification

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of section 194A, deals with such entities. The said clause reads as under:- iii) to such income credited or paid to- (a) any banking company to which the Banking Regulation Act, 1949 (10 of 1949), applies, or any co-operative society engaged in carrying on the business of banking (including a co-operative land mortgage bank

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

3) of section 194A, deals with such entities. The said clause reads as under:- iii) to such income credited or paid to- (a) any banking company to which the Banking Regulation Act, 1949 (10 of 1949), applies, or any co-operative society engaged in carrying on the business of banking (including a co-operative land mortgage bank

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

TDS is not to be deducted. It is very relevant to note that at the time of Acquisition Act was enacted, Central Government had issued a Notification No. SO 710 dated 16/02/1970 [1970] [Reported in 75 ITR (Stat) 106] which reads as under:- 58. Income-tax Act, 1961: Notification under sec. 194A(3)(iii)(f) Notification

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

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

TDS is not to be deducted. It is very relevant to\nnote that at the time of Acquisition Act was enacted, Central\n\nGovernment had issued a Notification No. SO 710 dated 16/02/1970\n[1970] [Reported in 75 ITR (Stat) 106] which reads as under:-\n58. Income-tax Act, 1961: Notification under sec. 194A(3)(iii)(f)\nNotification

ACIT, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK, BENGALURU

In the result, appeal filed by the Revenue is dismissed

TDS is not to be deducted. It is very relevant\nto note that at the time of Acquisition Act was enacted, Central\nGovernment had issued a Notification No. SO 710 dated 16/02/1970\n[1970] [Reported in 75 ITR (Stat) 106] which reads as under:-\n58.\nIncome-tax Act, 1961: Notification under sec. 194A(3)(iii)(f)\nNotification

THE CHIEF ACCOUNTS OFFICER,,MYSORE vs. ITO, MYSORE

In the result, the appeals of the assessee for all the three assessment years are allowed

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

194A(3)(iii)(f) would be admissible to an assessee who made payments to a company whose shares are held by the Govt. or held by the RBI or held by the corporation owned by RBI. Thereafter the Assessing Officer took into consideration the shareholding pattern of KUIDFC in Paragraph No.5.6 of the impugned order. The details read as under

CANARA BANK (ERSTWHILE SYNDICATE BANK),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, appeals of the assessee are partly allowed

Section 194A(1) shall not apply if the payment\nhas been made to certain entities. Clause (iii) of subsection (3) of\nsection 194A, deals with such entities. The said clause reads as under:-\niii) to such income credited or paid to- (a) any banking company to\nwhich the Banking Regulation Act, 1949 (10 of 1949), applies, or any\nco-operative

M/S. BANK OF BARODA(ERSTWHILE VIJAYA BANK),MUMBAI vs. ADDL.CIT, LTU, , BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\Nita No.234/Bang/2025\N Assessment Year: 2015-16\Nm/S. Bank Of Baroda (Erstwhile\Nvijaya Bank)\N2Nd Floor, Baroda Corporate Centre\Nbandra Kurla Complex\Nbandra (East)\Nmumbai 400 051\Npan No: Aaacv4791J\Nappellant\Nvs.\Naddl. Cit\Nltu\Nbangalore\Nrespondent\Nappellant By\N:\Nsmt. Lalitha Rameshwaran, A.R.\Nrespondent By\N:\Nsri Rajashekhar M., D.R.\Ndate Of Hearing\N:\N03.04.2025\Ndate Of Pronouncement\N:\N04.04.2025\No R D E R\Nper Keshav Dubey:\Nthis Appeal At The Instance Of The Assessee Is Directed Against\Nthe Order Of 1D. Cit(A)/Nfac Dated 23.12.2024 Vide Din & Order\Nno. Itba/Nfac/S/250/2024-25/1071453089(1) Passed U/S 250 Of\Nthe Act (In Short “The Act”) For The Ay 2015-16.\N2. The Assessee Has Raised The Following Grounds Of Appeal:\N1. The Order Of The Learned Cit(A) Is Against The Law & Facts Of The Case.\N2. The Order Passed By The Learned Cit(A) Is Against The Principles Of Natural Justice.\N2.

Section 194A(1) shall not apply if the payment\nhas been made to certain entities. Clause (iii) of subsection (3) of\nsection 194A, deals with such entities. The said clause reads as under:-\niii) to such income credited or paid to- (a) any banking company to\nwhich the Banking Regulation Act, 1949 (10 of 1949), applies, or any\nco-operative

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

194A. The assessee submits that these expenses are revenue in nature and has been debited in the Profit and Loss Account. 17.1 The AO as well as Ld. CIT(A) has disallowed the interest paid on delayed payment of TDS without appreciating the facts and the prevalent law of the land. It is the humble submission of the assessee that

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

194A. The assessee submits that these expenses are revenue in nature and has been debited in the Profit and Loss Account. 17.1 The AO as well as Ld. CIT(A) has disallowed the interest paid on delayed payment of TDS without appreciating the facts and the prevalent law of the land. It is the humble submission of the assessee that

M/S KARNATAKA EMTA COAL MINES LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), BANGALORE

In the result, assessee’s appeals are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillai

194A. The assessee submits that these expenses are revenue in nature and has been debited in the Profit and Loss Account. 17.1 The AO as well as Ld. CIT(A) has disallowed the interest paid on delayed payment of TDS without appreciating the facts and the prevalent law of the land. It is the humble submission of the assessee that