NO TDS on payment of Interest by co-operative society to its Members

Brief of the case: ITAT held in Almora Urban Co-operative Bank Ltd Vs ITO that TDS was not required to be deducted when co-operative society pays interest to its members as per sec 194A(3). Facts of the case : Assessee had paid interest to its members on term deposits without deducting TDS on it so, AO disallowed the expense and levied penalty u/s 201; aggrieved by which assessee challenged the same with CIT(A) who also confirmed the order of AO .Then assessee filed an appeal with ITAT. Contention of the assessee: Assessee was of the view that sec 194A(3) exempts the co-operative society from ...