Proviso to s.194A(3) upheld: taxing threshold tied to payer turnover/gross receipts valid; no relief for agricultural credit societies

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....The HC dismissed the writ petitions and upheld the constitutional validity of the proviso to s.194A(3) of the Income-tax Act as amended by the Finance Act, 2020. The court held that a proviso may operate substantively to alter a principal provision where legislative intent so indicates, and that the proviso here legitimately conditions the non-applicability of s.194A(1) on the payer's turnover/gross receipts without manifest arbitrariness or breach of legislative competence or fundamental rights. The petitioners, being primary agricultural credit societies not conducting banking as defined under the Banking Regulation Act, failed to establish entitlement to relief under s.194A(3)(iii). Accordingly, no interference was warranted.....