This compilation indexes twelve income-tax rulings — spanning ITAT benches and multiple High Courts — in which Section 194 of the Income-tax Act, 1961 was among the provisions engaged. The rulings range from June 2025 to May 2026 and arise in varied factual contexts: insurance compensation, land acquisition, co-operative societies, arbitration enforcement, and charitable institutions. The compilation is intended for in-house tax teams, Big-4 associates, and law-firm researchers who need a structured starting point for locating and reading the full judgments.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers should consult the full text of each judgment and seek qualified professional advice before acting on any information contained herein.

The statutory framework in one paragraph

Section 194 of the Income-tax Act, 1961 deals with the deduction of tax at source on dividends paid by a domestic company to a resident shareholder, but the provision is also referenced in a wider body of case law wherever the general obligation to deduct tax at source, or the identity of the correct deduction provision, is in dispute. Related provisions frequently appearing alongside Section 194 in litigated matters include Section 194A (interest other than on securities), Section 194J (fees for professional or technical services), Section 192 (salary), Section 201 (consequences of failure to deduct or pay), and Section 195 (payments to non-residents). The precise scope and applicability of Section 194 in any given fact situation is a question of law and fact that must be determined by reference to the full judgment.

The 12 rulings

1. National Insurance Company Ltd vs Ramesh Kumar Barman

Bench: Madhya Pradesh High Court
Date: 12 May 2026
Sections engaged: 194, 194A, 195, 30
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the insurance company under Section 30 of the Workmen's Compensation Act, 1923 before the Madhya Pradesh High Court at Jabalpur, challenging an order dated 31.05.2012 passed by the Commissioner, Workmen's Compensation, Labour Court, Jabalpur in Case No.109/2011/Fatal (Misc.). Per the source preview, the insurance company sought a refund of Rs.23,746/- claimed as TDS deducted on an interest amount, but the application was dismissed and the amount was directed to be kept in a fixed deposit. The High Court heard the matter on the question of maintainability as at the date of the order.

2. Darsing Sakharam Bhil And Others vs The Project Director Project

Bench: Bombay High Court
Date: 6 May 2026
Sections engaged: 194, 3G(1), 3G(5), 96
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Bombay High Court, Bench at Aurangabad, and the source preview indicates the matter involved multiple writ petitions — including Writ Petition Nos. 914, 2231, and 2232 of 2026 — filed by legal heirs of deceased petitioners against the Project Director, Project Implementation Unit, and the Competent Authority and Deputy Collector. The petitions appear to arise in a land acquisition or compensation context, with Section 194 cited alongside provisions of the National Highways Act; no further substantive holding is ascertainable from the source preview.

3. The Oriental Insurance Company Ltd vs Smt.Shivkumari Soni

Bench: Madhya Pradesh High Court
Date: 20 March 2026
Sections engaged: 194, 28
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition before the Madhya Pradesh High Court at Jabalpur (Misc. Petition No. 1298 of 2021) challenged an order dated 03.03.2021 passed by the Executing Court, to the extent that the insurance company had deducted TDS from interest payable to claimants and remitted the same to the Income Tax Department, which action was found erroneous by the Tribunal; the Tribunal had directed the TDS amount to be paid to the claimants directly. Per the source preview, the court noted that a Co-ordinate Bench at Gwalior in Oriental Insurance Co. Ltd. vs. Swaroopi Bai and others (2020 ACJ 72) had held that such deduction could be made from the claim amount and had allowed an identically placed petition, with the preview also reproducing a passage on the strict construction of exemption provisions.

4. Executive Engineer & Ado vs Jayabal

Bench: Madras High Court
Date: 14 November 2025
Sections engaged: 115, 194
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter came before the Madras High Court as Civil Revision Petitions Nos. 4652, 4671, and 4665 of 2025, filed by the Tamil Nadu Housing Board, Villupuram, seeking to set aside an order dated 10.07.2025 passed in E.P.Nos.149, 148, and 147 of 2012 in L.A.O.P.Nos.110, 92, and 90 of 1996 by the Principal Subordinate Judge, Villupuram. Per the source preview, the respondents had filed execution petitions for attachment and sale of immovable properties belonging to the petitioner, and the execution court had ascertained the actual amounts due; no further substantive holding on Section 194 is ascertainable from the source preview.

5. National Co-Operative Consumer'S vs Mirah Dekor Pvt Ltd Formerly Known As

Bench: Bombay High Court
Date: 3 November 2025
Sections engaged: 194
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter arose as Commercial Arbitration Petition No.1380 of 2019 before the Bombay High Court (Ordinary Original Civil Jurisdiction). Per the source preview, the petitioner — National Co-operative Consumers' Federation of India Ltd. — had been directed to pay amounts awarded directly to the Income-Tax Authorities forthwith, subject to appeals filed by Mirah, in view of an order of the Joint Commissioner of Income-Tax attaching any payments due to Mirah of up to Rs.17 crores; the factual background indicates Mirah supplies consumer items including food stuff and had been empanelled by the Federation as a supplier of groceries.

6. Income Tax Officer(TDS), Alappuzha vs Muthoot Health Care Private Limited

Bench: Income Tax Appellate Tribunal - Cochin
Date: 27 October 2025
Sections engaged: 192, 194(2), 194J, 201(1), 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The Revenue's appeal (ITA No.517/COCH/2025) for Assessment Year 2018-2019 was directed against the order dated 22/05/2025 passed by the Additional/Joint Commissioner of Income Tax (Appeals), and the respondent assessee's PAN is recorded as TVDM01878C per the source preview. The source preview indicates the factual matrix involved questions relating to the characterisation of engagement — referencing criteria such as fixed working hours, eligibility for employee benefits including PF, gratuity and leave, prohibition from engaging in other similar work, and disciplinary control — relevant to determining whether the applicable deduction provision was under Section 192 or Section 194J; no dispositive holding is ascertainable from the source preview alone.

7. International Creations Private vs Income Tax Officer, Ward-1, Surat

Bench: Income Tax Appellate Tribunal - Surat
Date: 26 September 2025
Sections engaged: 194, 2(22)(e), 201, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee's appeal (ITA No.742/SRT/2024) for Assessment Year 2015-16 before the ITAT Surat Bench emanated from the order passed under Section 250 of the Income-tax Act, 1961, dated 14.05.2024, by the Commissioner of Income-tax (Appeals); the assessee's PAN is recorded as AAACI8917P per the source preview. The appeal was heard on a hybrid basis; no further substantive holding is ascertainable from the source preview beyond the procedural posture.

8. Pronounced On:11.09.2025 vs Union Of India & Ors

Bench: Jammu & Kashmir High Court
Date: 11 September 2025
Sections engaged: 119(2)(b), 139, 194, 237, 239
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(C) No. 2058/2019) was preferred before the High Court of Jammu & Kashmir and Ladakh at Jammu (through virtual mode from Srinagar), seeking a direction to the respondents to refund 10% amounts deducted as TDS from compensation assessed on account of damage caused to the petitioners' respective houses due to construction of a nearby tunnel, along with interest at the rate of 18% per annum. Per the source preview, the National Highway Authority of India had commenced construction of four-laning of a National Highway in District Ramban, during which surrounding structures were damaged due to blasting, and the PWD department conducted assessment of the damaged structures.

9. Mirza Ahmed Baig vs Pavushetty Srinivas

Bench: Telangana High Court
Date: 18 August 2025
Sections engaged: 17, 194, 195, 26
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (A.S.No.75 of 2020) was filed before the High Court for the State of Telangana at Hyderabad by the appellant-defendant, aggrieved by the judgment of the court below. Per the source preview, the dispute involved a principal amount under an agreement note dated 09.04.2010 for Rs.10,00,000/-, with interest claimed at 2% per month from 09.04.2010 to 31.03.2013 (68 months and 11 days) amounting to Rs.13,67,333/-, and legal notice charges of Rs.3,000/-, totalling Rs.23,70,333/-; no further substantive holding on Section 194 is ascertainable from the source preview.

10. U.352. Periyakadambur Primary vs The Chairperson

Bench: Madras High Court
Date: 26 June 2025
Sections engaged: 194
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.Nos.855 & 292 of 2024 and 35397 of 2023) was filed before the Madras High Court under Article 226 of the Constitution of India by U.352. Periyakadambur Primary Agricultural Co-operative Credit Society Ltd., represented by its Secretary, praying for a writ of mandamus forbearing respondents 3 and 4 from deducting 2% TDS on the withdrawal of the petitioner from its savings bank account maintained at the fourth respondent, Kancheepuram Central Co-operative Bank Ltd. The respondents included the Chairperson, Central Board of Direct Taxes, and the State of Tamil Nadu, among others.

11. Ajinkya Madhyamik Shikshak Sevak Sah vs Income Tax Officer, Ward-2, Satara

Bench: Income Tax Appellate Tribunal - Pune
Date: 18 June 2025
Sections engaged: 139(1), 143(1), 143(1)(a), 194, 194M, 80A, 80P, 80P(2)(a)
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee's appeal (ITA No.2214/PUN/2024) for Assessment Year 2020-21 was filed before the ITAT Pune SMC Bench against the order dated 15.10.2024 of the Additional/Joint Commissioner of Income Tax (Appeals)-5, Delhi; the assessee's PAN is recorded as AAAAA3002D per the source preview. Per the source preview, the assessee is a patsanstha engaged in accepting deposits from its members and providing credit facilities, earning interest on loans to members, with its income claimed as eligible for deduction under Section 80P of the Income-tax Act; no further substantive holding is ascertainable from the source preview alone.

12. Institute Of Clinical Research India vs CIT(A), Dehradun

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 13 June 2025
Sections engaged: 11(1), 11(5), 12A, 13, 194, 194J, 2(15), 28, 29, 30, 40(a), 60
Outcome: Outcome not specified in source
Procedural / substantive ground: The assessee's appeal (ITA No.45/DDN/2024) for Assessment Year 2012-13 before the ITAT Dehradun SMC Bench arose against the CIT(A)/NFAC order (DIN and order no. ITBA/NFAC/S/250/2023-24/1061095391(1), dated 19.02.2024), involving proceedings under sections 147 r.w.s. 144 of the Act; the assessee's PAN is recorded as AABAI3710P per the source preview. The matter was proceeded ex-parte, as the case was called twice and none appeared at the assessee's behest; the source preview notes partial monetary figures attributed to named individuals but does not disclose a dispositive holding.

Patterns across these 12 rulings

TDS on compensation and interest payments is a recurring flashpoint. Multiple cases in this compilation — including the Madhya Pradesh High Court matters (cases 1 and 3) and the Jammu & Kashmir High Court matter (case 8) — involve disputes over whether TDS was correctly deducted on interest or compensation amounts paid in motor accident or infrastructure damage contexts, and who bears the burden of that deduction or its refund.
Co-operative societies and institutions raise distinct TDS and deduction questions. Cases 10 and 11 both involve co-operative entities contesting TDS deduction obligations — one a primary agricultural co-operative credit society at the Madras High Court, and one a patsanstha at ITAT Pune — suggesting that the intersection of Section 194 with the co-operative sector's claimed exemptions continues to generate litigation.
Employment characterisation drives TDS provision selection at ITAT. Case 6 (ITAT Cochin) illustrates a category of dispute where the correct deduction provision depends on whether the engaged persons are employees or independent contractors, with criteria such as fixed working hours, employee benefits, and disciplinary control being cited in the source preview as relevant factors.
Income-Tax attachment orders intersect with civil and arbitration proceedings. Case 5 (Bombay High Court, arbitration) demonstrates that Income-Tax Authority attachment orders — in that instance up to Rs.17 crores — can require civil courts and arbitral enforcement proceedings to redirect payment flows directly to tax authorities, creating procedural complexity at the intersection of civil and revenue law.
Outcomes are frequently unspecified in the source corpus. Across all 12 rulings, the outcome_direction field records "Outcome not specified in source," which is itself a pattern: researchers using this index as a starting point should treat it as a finding aid only and consult the full text of each judgment for the dispositive order.

How to use this compilation

This index is a structured finding aid. Each entry provides the formal identity fields (bench, date, sections engaged) drawn from a structured legal corpus and the procedural or factual ground drawn from the available text preview of the source judgment. Because all outcome directions in this compilation are recorded as "Outcome not specified in source," researchers must obtain and read the full text of each judgment — available through indiankanoon.org or the relevant court portal — before drawing any conclusion about the legal position established by a ruling.

Before relying on any ruling, researchers should verify whether the order has been stayed, appealed, or reversed by a higher forum. An ITAT order may have been challenged before a High Court; a High Court order may be the subject of a Special Leave Petition before the Supreme Court. The CBDT also issues circulars and instructions that may affect the practical application of a provision even where a court ruling is final. Checking for parallel administrative guidance is therefore an essential step in any complete research workflow.

Section 194 appears in this compilation in a wide range of factual contexts — motor accident compensation, land acquisition, arbitration enforcement, co-operative societies, charitable institutions, and employment characterisation — which means that a ruling in one context may have limited persuasive value in a materially different fact situation. Researchers should identify the specific factual and legal matrix relevant to their query and use this compilation only as a gateway to the primary sources, not as a substitute for reading those sources in full.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 194 TDS: 12 Income-Tax Rulings from ITAT and High Courts (2025–2026)