DCIT v. Sahara India Financial Corporation Ltd. (2020) 183 ITD 266 /194 DTR 153/207 TTJ 555 (Delhi)(Trib.)

S. 194A : Deduction at source-Interest other than interest on securities-Interest payable to any of individual account holder did not exceed Rs. 2,500 in a Financial year-Not liable to deduct tax at source. [S. 201]

Tribunal held that interest payable to any of individual account holder did not exceed Rs. 2,500 in a Financial year the was not required to deduct tax at source. Tribunal also held that any sum credited to suspense account or ‘interest payable account’ would be deemed to be credited for purpose of tax deduction at source and, therefore, if in individual account interest payments exceed Rs. 2500, on crediting of same to different account than account of depositors, TDS liability of deductor cannot be eliminated. (AY.1996-97)