The petitioners  are Primary Agricultural Credit Societies, they are co-operative societies inter alia engaged in carrying on the business of banking and they are therefore entitled to receive the interest amounts earned by them from deposits made with the State Treasuries and the District Co-operative Banks respectively without deduction of tax at source. They contend that in respect of the amounts deposited with the State Treasury, they would be exempted from the requirement of suffering tax deduction at source on an account of the provisions of S.  194A(3)(iii)(a), and in respect of the interest earned from deposits with the District Co-operative Banks, they would be entitled to a similar exemption on account of S.  194A(3)(iii)(v) of the Act.  On writ the Court held that,deposits made by the petitioner societies with the Co-operative Banks, they would be entitled to the benefit of exemption under S.194  4A(3)(iii)(v) of the Act and, in respect of the deposits made by the petitioner societies with the Treasury, they will not be entitled to the benefit of exemption under S. 194A(3)(iii)(a) of the Act. (SJ)  (WP No.7795 of 2019 dt 3-12-2019)