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20 results for “TDS”+ Section 194A(3)(i)clear

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Mumbai377Delhi265Bangalore169Chennai108Nagpur105Chandigarh99Kolkata96Karnataka70Pune51Jaipur51Ahmedabad41Hyderabad36Cochin20Visakhapatnam19Panaji13Rajkot12Raipur12Jodhpur10Surat8SC8Telangana8Indore6Jabalpur5Cuttack5Ranchi4Kerala4Lucknow4Amritsar3Patna3Allahabad3Guwahati2J&K2

Key Topics

Section 194A34Section 197A30Section 26319Deduction18TDS18Section 20116Section 4014Section 143(3)13Section 80P13Section 201(1)

M/S WAYANAD DIST. CO.OP BANK LTD.,WAYANAD vs. ITO(TDS), KOZHIKODE

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 958/COCH/2022[2016-17]Status: DisposedITAT Cochin28 Feb 2023AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

TDS thereon at the rate in force. The Explanation below sub-section (1) of Section 194A of the Act clarifies that where any income by way of interest is credited to any account, whether called “interest payable account” or “suspense account” or any other name in the books of account of the payer, such credit shall be deemed

9
Addition to Income7
Condonation of Delay5

M/S WAYANAD DIST. CO.OP BANK LTD.,WAYANAD vs. ITO(TDS), KOZHIKODE

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 959/COCH/2022[2017-18]Status: DisposedITAT Cochin28 Feb 2023AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

TDS thereon at the rate in force. The Explanation below sub-section (1) of Section 194A of the Act clarifies that where any income by way of interest is credited to any account, whether called “interest payable account” or “suspense account” or any other name in the books of account of the payer, such credit shall be deemed

M/S WAYANAD DIST. CO.OP BANK LTD.,WAYANAD vs. ITO(TDS), KOZHIKODE

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 960/COCH/2022[2018-19]Status: DisposedITAT Cochin28 Feb 2023AY 2018-19

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

TDS thereon at the rate in force. The Explanation below sub-section (1) of Section 194A of the Act clarifies that where any income by way of interest is credited to any account, whether called “interest payable account” or “suspense account” or any other name in the books of account of the payer, such credit shall be deemed

M/S WAYANAD DIST. CO.OP BANK LTD.,WAYANAD vs. ITO(TDS), KOZHIKODE

In the result, the appeals filed by the assessee are partly allowed for statistical purposes and the stay petitions are dismissed

ITA 961/COCH/2022[2019-20]Status: DisposedITAT Cochin28 Feb 2023AY 2019-20

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Joseph Markose, Sr. AdvocateFor Respondent: Smt. J.M. Jammuna Devi, Sr. DR
Section 194ASection 201Section 201(1)Section 250

TDS thereon at the rate in force. The Explanation below sub-section (1) of Section 194A of the Act clarifies that where any income by way of interest is credited to any account, whether called “interest payable account” or “suspense account” or any other name in the books of account of the payer, such credit shall be deemed

THOMAS JOHN MUTHOOT,THIRUVANANTHAPURAM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1 , THIRUVALLA, TRIVANDRUM

In the result, appeal filed by the assessee is dismissed

ITA 896/COCH/2023[2008-09]Status: DisposedITAT Cochin21 Oct 2024AY 2008-09

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Thomas John Muthoot Dcit, Circle - 1 Muthoot Centre, Punnen Road Thiruvalla Vs. Thiruvananthapuram 695001 [Pan: Abnpt4694B] (Appellant) (Respondent)

For Appellant: Shri Srinivasan, CAFor Respondent: Shri Sanjit Kumar Das
Section 194ASection 40

TDS under the provisions of section 194A r.w.s. 40(a)(ia) of the Income Tax Act, 1961 the Act amounting to Rs.31,77,000/- only. 3

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 465/COCH/2025[2013-2014]Status: DisposedITAT Cochin22 Aug 2025AY 2013-2014

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

TDS only on a sum of Rs. 1,32,42,920/- and on the balance amount no tax was deducted at source treating it as mere reimbursement of expenditure to MPCMS. The said payee, i.e. MPCMS also raised different bills. The AO was of the opinion that the money paid towards management consultancy charges under composite contract and the contract

MUTHOOT FINCORP LIMITED,TRIVANDRUM vs. ITO,CIRCLE CENTRAL, TRIVANDRUM

In the result, the appeals filed by the assessee stand dismissed

ITA 496/COCH/2025[2010-2011]Status: DisposedITAT Cochin22 Aug 2025AY 2010-2011

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

TDS only on a sum of Rs. 1,32,42,920/- and on the balance amount no tax was deducted at source treating it as mere reimbursement of expenditure to MPCMS. The said payee, i.e. MPCMS also raised different bills. The AO was of the opinion that the money paid towards management consultancy charges under composite contract and the contract

MUTHOOT FINCORP LIMITED,THIRUVANANTHAPURAM vs. JCIT, SPECIAL RANGE, THIRUVANANTHAPURAM

In the result, the appeals filed by the assessee stand dismissed

ITA 464/COCH/2025[2006-2007]Status: DisposedITAT Cochin22 Aug 2025AY 2006-2007

Bench: Shri Inturi Rama Rao, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri R. Krishnan, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 148Section 194CSection 40

TDS only on a sum of Rs. 1,32,42,920/- and on the balance amount no tax was deducted at source treating it as mere reimbursement of expenditure to MPCMS. The said payee, i.e. MPCMS also raised different bills. The AO was of the opinion that the money paid towards management consultancy charges under composite contract and the contract

KERALA SHIPPING AND INLAND NAVIGATION CORPORATION LIMITED,ERNAKULAM vs. DEPUTY COMMISSIONER OF INCOME TAX , CORPORATE CIRCLE 1(1), KOCHI

In the result appeal of the assessee is hereby allowed

ITA 78/COCH/2024[2018-19]Status: DisposedITAT Cochin21 Oct 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Kerala Shipping & Inalnd Dcit, Corporate Circle - 1(1) Navigtation Corporation C.R. Building, I.S. Pres Road 38/924-A, Udaya Nagar Road Kochi 682018 Vs. Gandhi Nagar Kochi 682020 [Pan: Aabck4818L] (Appellant) (Respondent)

For Appellant: Shri K. Gopi, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 1Section 115BSection 143(3)Section 199Section 263Section 69Section 69C

section 263 of the Act set aside the assessment order for fresh assessment with the following direction: “Hence, the Assessment Order u/s 143(3) dated 19/05/2021 is set aside to the Assessing Officer to consider the below matter: 1) For AY 2018-19 assessee had declared Rs.80,70,207/- as the interest Income (Income from other Source) in the return

ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 647/COCH/2025[2020-21]Status: DisposedITAT Cochin29 Oct 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri Anandan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 191Section 194ASection 197ASection 201Section 201(1)

3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 645/Coch/2025 for AY 2018-19 are stated herein. Esaf Small Finance Bank Ltd. 4. Brief facts of the case are that the appellant is a company engaged in the business of banking. The Income Tax Officer-TDS, Thrissur had conducted survey operations

ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 646/COCH/2025[2019-20]Status: DisposedITAT Cochin29 Oct 2025AY 2019-20

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri Anandan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 191Section 194ASection 197ASection 201Section 201(1)

3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 645/Coch/2025 for AY 2018-19 are stated herein. Esaf Small Finance Bank Ltd. 4. Brief facts of the case are that the appellant is a company engaged in the business of banking. The Income Tax Officer-TDS, Thrissur had conducted survey operations

ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 648/COCH/2025[2022-23]Status: DisposedITAT Cochin29 Oct 2025AY 2022-23

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri Anandan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 191Section 194ASection 197ASection 201Section 201(1)

3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 645/Coch/2025 for AY 2018-19 are stated herein. Esaf Small Finance Bank Ltd. 4. Brief facts of the case are that the appellant is a company engaged in the business of banking. The Income Tax Officer-TDS, Thrissur had conducted survey operations

ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 645/COCH/2025[2018-19]Status: DisposedITAT Cochin29 Oct 2025AY 2018-19

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri Anandan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 191Section 194ASection 197ASection 201Section 201(1)

3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 645/Coch/2025 for AY 2018-19 are stated herein. Esaf Small Finance Bank Ltd. 4. Brief facts of the case are that the appellant is a company engaged in the business of banking. The Income Tax Officer-TDS, Thrissur had conducted survey operations

ESAF SMALL FINANCE BANK LIMITED,THRISSUR vs. ITO, TDS WARD, THRISSUR

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

ITA 277/COCH/2025[2021-22]Status: DisposedITAT Cochin06 Jun 2025AY 2021-22

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2021-22 Esaf Small Finance Bank Ltd. .......... Appellant Building No. Vii/83//8,Esaf Bhavan, Thirssur- Palakkad Nh, Mannuthy P.O., Thrissur 680651 [Pan: Aaece2619Q] Vs. The Income Tax Officer - Tds, Thrissur .......... Respondent Appellant By: Shri Anandan, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.05.2025 Date Of Pronouncement: 26.06.2025

For Appellant: Shri Anandan, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 133ASection 191Section 194ASection 197ASection 201Section 201(1)

3 Esaf Small Finance Bank Ltd. 4. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 5. The learned counsel for the assessee submits that the appellant is not in default in terms of the provisions of section 201(1) of the Act as the appellant had duly complied with the provisions of section 197A

K. THOMAS VARGHESE,PIRAVAM vs. THE ACIT, ALUVA

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

ITA 83/COCH/2022[2011-12]Status: DisposedITAT Cochin30 Jun 2022AY 2011-12

Bench: Shri George George K. & Shri Laxmi Prasad Sahushri K. Thomas Varghese Acit, Circle - 1 Manakunnathu Aluva Vs. Piravom 686664 Pan – Aaspv5029L Appellant Respondent

For Appellant: Shri S.R. Lokanathan, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 194ASection 40

TDS under section 194A and not an item disallowable U/S 40(a)(i) of the Act. The appellant was denied an opportunity to furnish certificate in Form No. 26A as provided in the Act & Rules. 9. The first appellate authority had also not considered the fact that the rental charges is an inevitable expenditure for the retail shop for consumer

M/S. NEDUMATTOM SERVICE CO-OP BANK LTD,IDUKKI vs. THE ITO, THODUPIZHA

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

ITA 189/COCH/2021[2015-16]Status: DisposedITAT Cochin27 Jun 2022AY 2015-16

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am

For Appellant: Sri.Arun Raj, AdvocateFor Respondent: Smt.J.M.Jamunna Devi, Sr.DR
Section 142(1)Section 143(3)Section 2(19)Section 263Section 80Section 80PSection 80P(2)(d)

section 80P(2)(d). Admittedly, the assessee during the relevant assessment years had only interest from M/s.Idukki District Co-operative Bank Ltd. The Hon’ble Kerala High Court in Kallara Service Co-operative 6 ITA No.189/Coch/2021. M/s.Nedumattom SCB Limited. Bank Ltd, Kottayam and others Vs. The CIT (TDS), Cochin (WP (C)9415 of 2019) (judgment dated 18.10.2019) has decided that

VADAKKEVILA SERVICE CO-OPERATIVE BANK LTD,KOLLAM vs. THE ITO, KOLLAM

Appeal is allowed in above terms

ITA 478/COCH/2023[2017-18]Status: DisposedITAT Cochin25 Sept 2024AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Ms.Anoopa, AdvocateFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 143(3)Section 194ASection 40Section 56Section 80PSection 80P(2)Section 80P(2)(a)

3 read with section 56 of the BR Act, 1949, the primary co-operative bank cannot be a primary agricultural credit society. As such co-operative bank must be engaged in the business of banking as defined by section 5(b) of the BR Act, 1949, which means accepting, for the purpose of lending or investment, of deposits of money

BHARATH RASIKLAL SHAH,COCHIN vs. PCIT KOCHI-1, KOCHI

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

ITA 744/COCH/2024[2017-18]Status: DisposedITAT Cochin10 Jun 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Advocate &
Section 143Section 143(3)Section 144Section 147Section 194ASection 263Section 263(1)

Section 263 order would expose him to the threat of vindicative action by the Assessing Officer (NFAC) u/s 144 (Best judgment assessment) as the same is based on the grounds of erroneous assessment and prejudicial to the revenue. The apprehension gains more significance as the PCIT is aware that the Appellant has already submitted that he has deposited original sales

PALLATH NAFEESA,MALAPPURAM vs. ITO, TIRUR

In the result, appeal filed by the assessee allowed

ITA 118/COCH/2023[2015-16]Status: DisposedITAT Cochin03 Oct 2024AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Pallath Nafeesa The Income Tax Officer Poolakkodan House Tirur Athirumada, Punnathala Vs. Tirur, Malappuram 676552 [Pan: Alipn9300R] (Appellant) (Respondent)

For Appellant: Shri Shaji Paulose, CAFor Respondent: Smt. Girly Albert, Sr. D.R
Section 10(37)Section 145ASection 194ASection 197Section 28Section 34Section 56(2)(viii)Section 57

TDS reported in70 taxmann.com 45. The relevant finding of the Hon’ble Bench is extracted as under: “10. In the facts of the present case, it is an admitted position that the interest on which the tax is sought to be deducted at source under section 194A of the Act is interest under section

THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. DCIT,TDS, THIRUVANANTHAPURAM

In the result, appeal filed by the assessee stands partly allowed

ITA 1061/COCH/2024[2015-16]Status: DisposedITAT Cochin16 May 2025AY 2015-16

Bench: Shri George George K., Vp & Shri Inturi Rama Rao, Am

For Appellant: Shri Naresh C., CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 10Section 194ASection 201Section 297

194A of the Act after accepting Form 15H form the persons who are not eligible to submit the same. Accordingly, the appellant bank was asked to explain as to why it should not be treated as assessee in default u/s. 201 of the Act. In response to the show cause notice the appellant filed a detailed explanation. Finally, after considering