Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Cooperative bank appealed against TDS obligations on interest payments to cooperative societies and a temple trust. ITAT held that under Sec 194A(3)(v), cooperative banks are exempt from TDS deduction on interest payments to other cooperative societies, regardless of membership status. The exemption applies broadly to inter-cooperative society transactions. For interest paid to Jagan Nath Temple, ITAT ruled no TDS requirement exists under Sec 194A(3)(iii)(f) as the temple qualifies as a government-financed entity per notification 3489 dated 22/10/1970. The tribunal emphasized that the statutory exemption is explicit and unambiguous, requiring no additional conditions. Appeal allowed, affirming appellant's position on non-deduction of TDS.
Cooperative bank appealed against TDS obligations on interest payments to cooperative societies and a temple trust. ITAT held that under Sec 194A(3)(v), cooperative banks are exempt from TDS deduction on interest payments to other cooperative societies, regardless of membership status. The exemption applies broadly to inter-cooperative society transactions. For interest paid to Jagan Nath Temple, ITAT ruled no TDS requirement exists under Sec 194A(3)(iii)(f) as the temple qualifies as a government-financed entity per notification 3489 dated 22/10/1970. The tribunal emphasized that the statutory exemption is explicit and unambiguous, requiring no additional conditions. Appeal allowed, affirming appellant's position on non-deduction of TDS.
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