Petitioners were Primary Agricultural Co-operative Credit Societies, primarily engaged in lending money to members of Society for agriculture and allied activities. State Government implemented Pongal welfare scheme through these Societies whereby allotment for a district would be made to a Central Co-operative Bank which would be withdrawn by petitioners in bulk and distributed to beneficiaries. Such withdrawal of money was considered to be income of petitioners on which Central Co-operative Bank was liable to deduct tax at source under section 194N at 2 per cent where payment in cash exceeded Rs. 1 crore during previous year. Central Co-operative Bank issued a Circular to Societies to strictly adhere to provisions of section 194N.  Primary Societies were only acting as Facilitators to pass on welfare scheme being implemented by State Government, they chose to challenge circulars issued by respective District Central Co-operative Banks. In similar previous petitions, a Mandamus was issued directing Ministry of Finance, Government of India and CBDT to immediately examine representation of Tamil Nadu Government for exemption of Societies from section 194N after affording opportunity of hearing to Government and all stakeholders through public notice.(Madurai Bench of the Madras High Court in the matter of A.2979 Thirumohur Primary Agricultural Co-operative Credit Society Ltd. v. ITO [W.P.(MD) Nos.4499, 4536 and 4592 of 2023, dated 3-3-2023). Revenue submitted that within a reasonable period, request made by Government of Tamil Nadu would be considered and a decision would be taken. Further time of six weeks was  granted to Revenue within which Ministry of Finance, Government of India and CBDT would decide request made by Government of Tamil Nadu for co-operative societies seeking exemption from section 194N and pass orders thereon.