Assessee is a Co-Operative Society  received deposits and thereafter redeemed same. They were also granting loans to its members. Revenue issued notices directing assessee-Co-Operative society to deduct TDS under section 194A for interest income which exceeded Rs. 40,000 and TDS under section 194N for cash withdrawals exceeding Rs. 20 lakhs..  Assessee-Co-operative societity claimed that they were acting as a business correspondents to pass on cash benefits as mandated by State Government to distribute same to farmers to meet out their minimum requirements i.e., to buy fertilizers, etc. and also for providing reliefs such as Pongal enam, flood relief, etc. and, thus, would be exempt under section 194N. On writ dismissing the petition the Court held that  that assessee-c had not established that they had distributed cash benefits as mandated by State Government to its members as well as non-members in terms of guidelines of Reserve Bank of India. Active involvement of assessee to act as a business correspondents of a State Government for distribution of cash benefits to its members as well as to non-members was not a banking transaction but a transaction other than banking activities in nature. Since Revenue had merely brought into knowledge of assessee-societies to comply with said provisions of sections 194A and 194N, same could not be challenged under article 226 of Constitution of India. Followed, S.N. 299 Molasi Primary Agricultural  Co-Operative Society Ltd  (2023) 330 CTR 100/ (2022) 220 DTR 217 (Mad)(HC)