https://www.taxtmi.com/caselaws?id=11457 An administrative circular under the Income-tax Act cannot narrow a statutory exemption by adding a distinction not found in the provision itself. Section 194A(3)(v) exempts interest paid or credited by a co-operative society to a member from tax deduction at source, and where "member" is not defined in the Act, its meaning is taken from the governing co-operative law. Because that law included nominal, associate and sympathiser members, the circular's attempt to confine the exemption to duly registered members exceeded the Board's power under section 119 and was inconsistent with the parent Act. en-us Fri, 05 Sep 2003 00:00:00 +0530 Wed, 29 Apr 2026 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11457 An administrative circular under the Income-tax Act cannot narrow a statutory exemption by adding a distinction not found in the provision itself. Section 194A(3)(v) exempts interest paid or credited by a co-operative society to a member from tax deduction at source, and where "member" is not defined in the Act, its meaning is taken from the governing co-operative law. Because that law included nominal, associate and sympathiser members, the circular's attempt to confine the exemption to duly registered members exceeded the Board's power under section 119 and was inconsistent with the parent Act. Case-Laws Income Tax Fri, 05 Sep 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11457