https://www.taxtmi.com/caselaws?id=780763 A turnover-based proviso restricting the TDS exemption for specified co-operative societies was upheld as a valid fiscal classification with a rational nexus to the statutory scheme, and the Article 14 challenge based on unreasonable classification and manifest arbitrariness failed. The Court also held that section 80P gives a deduction, not an exclusion of the income from the tax net, so the proviso to section 194A(3) was not beyond legislative power and could validly qualify the main provision. Primary agricultural credit societies were further held not to fall within the banking-company exemption under section 194A(3)(iii)(a), so they were not entitled to that benefit. en-us Sat, 25 Oct 2025 00:00:00 +0530 Mon, 11 May 2026 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780763 A turnover-based proviso restricting the TDS exemption for specified co-operative societies was upheld as a valid fiscal classification with a rational nexus to the statutory scheme, and the Article 14 challenge based on unreasonable classification and manifest arbitrariness failed. The Court also held that section 80P gives a deduction, not an exclusion of the income from the tax net, so the proviso to section 194A(3) was not beyond legislative power and could validly qualify the main provision. Primary agricultural credit societies were further held not to fall within the banking-company exemption under section 194A(3)(iii)(a), so they were not entitled to that benefit. Case-Laws Income Tax Sat, 25 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780763