Petitioners, primary agricultural co-operative societies (PACCSs), were working as an intermediary between bank and agriculturists in advancing crop and fertilizing loans for agriculturists. They filed writ petition challenging circulars issued by District Central Co-operative Banks that refer to mandate of section 194N for deduction of tax on cash withdrawal and contended that TDS should not be deducted on withdrawals made by them since beneficiary of such cash was agriculturists. Dismissing the petition the Court held that provision of section 194N is non-negotiable except in line with specific exceptions stipulated under proviso 4 and thus petitioners should seek redressal under such in-built statutory mechanism. It was open for banks to establish before Assessing Officer after examination of evidences that sums withdrawn by member societies did not represent income in their hands, however, said examination could only be carried out at instance of societies and not at instance of banks, who are payers, with statutory responsibility to deduct.