Summary
- The ITAT Agra has ruled that the State Bank of India cannot be treated as an assessee in default for not deducting TDS on Leave Fare Concession reimbursements during periods governed by a Madras High Court interim direction.
- This decision stems from appeals concerning assessment years 2016-17 and 2017-18, where the bank was bound by judicial orders preventing tax deductions.
- The Tribunal emphasized that compliance with a judicial command cannot be deemed a default under Section 201(1) of the Income Tax Act.
- This ruling clarifies the distinction between substantive tax liability and deductor responsibilities, potentially impacting similar cases across India.
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