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    <title>2026 (6) TMI 502 - KERALA HIGH COURT</title>
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    <description>The proviso inserted in Section 194A(3) of the Income-tax Act, 1961, was upheld as a valid classification because it lawfully limited the tax-deduction exemption for co-operative societies by turnover and interest thresholds, and the challenge based on arbitrariness failed. Co-operative banks were held not to derive their exemption position from the new proviso, since the CBDT explanatory note to the Finance Act, 2015 continued to govern the practical exemption for time deposits credited to co-operative society depositors. No interference was warranted with the clarification protecting transactions covered by interim orders, as those transactions had been acted upon during the pendency of the writ petitions. The appeals were dismissed.</description>
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