Section 33BA: TDS not deductible on Interest on Site Restoration Fund

DCIT (TDS) Vs. State Bank of India (ITAT Delhi)

ITAT has examined the question of whether the Site Restoration Fund Account (SRF A/c) is a time deposit and held that it is not. Therefore, in view of the provisions of section 194A (3) (vii) it has held that the provisions of section 194A(1) have no application to the assessee’s case. Thus, once the ITAT has given a finding of fact that the SRF a/c is not a time deposit, the AO’s action in revisiting the issue on the basis of earlier submission made by the assessee in

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