Circulars mandating compliance of section 194A & 194N by co-op societies cannot be challenged under Article 226

Chennimalai Siragiri Murugan Primary Handloom Weaver’s Cooperative Society Ltd. Vs ITO (Madras High Court) Madras High Court held that circulars dated 16.03.2021, 05.08.2021 and 01.04.2021 mandating compliance of provisions of section 194A and 194N of the Income Tax Act by co-operative societies cannot be challenged under Article 226 of the Constitution of India. Facts- Vide the present petition, the petitioners/Co-operative Societies have challenged the three circulars dated 16.03.2021, 05.08.2021 and 01.04.2021 issued by the 3rd respondent. The said circulars mandate the compliance of...