Citizen Credit Co-operative Bank Ltd. vs. ITO (TDS)

Parties Involved

Facts Summary

The assessee, Citizen Credit Co-operative Bank Ltd., is a multi-state cooperative society registered under the Multi-State Co-operative Societies Act, 1984, and holds a banking license from the Reserve Bank of India (RBI). It was originally registered in 1920 and achieved 'Scheduled Bank' status in 1996. The bank has 24 branches in Mumbai, each with a separate TAN registration. The case pertains to the non-deduction of TDS on interest paid by the bank to registered cooperative societies and other persons. The Assessing Officer (AO) issued a notice under section 201 of the Income-tax Act, 1961, and held that the bank was liable to deduct TDS under section 194A of the Act. The bank appealed this decision to the Commissioner of Income-tax (Appeals) [CIT(A)], which upheld the AO's order. The bank then appealed to the Income-tax Appellate Tribunal (ITAT).…

Legal Issues

• 1. Whether the appellant, a multi-state cooperative bank, was under an obligation to deduct tax at source on interest paid or credited on fixed deposits placed by cooperative societies as per section 194A(1) read with section 194A(3) of the Income-tax Act, 1961.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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