This compilation indexes twelve High Court rulings from across India — Gujarat, Madras, Delhi, and Bombay — in which Section 194A of the Income Tax Act, 1961 was engaged. The cases span the period from January 2020 to September 2025 and arise predominantly in the context of insurance companies, compensation awards under workmen's compensation and motor accident claims legislation, and income-tax assessments involving interest income. The compilation is intended as a structured research reference for in-house tax teams, Big-4 associates, and law firm researchers who need a rapid index of how Section 194A questions have reached the High Courts in recent years.

Research index only. This page is a structured case-law index drawn from publicly available court records. Nothing on this page constitutes legal or tax advice. Readers must verify each ruling against the full judgment text and check for subsequent stays, appeals, or reversals before relying on any entry.

The statutory framework in one paragraph

Section 194A of the Income Tax Act, 1961 requires any person (other than an individual or Hindu undivided family not subject to tax audit under the relevant threshold) who is responsible for paying to a resident any income by way of interest other than interest on securities to deduct income tax at source at the rates in force at the time of credit or payment, whichever is earlier. The section carves out specific exemptions under sub-section (3), including payments by banking companies and co-operative societies below prescribed thresholds, interest paid to certain entities, and other categories notified by the Central Government. The provision interacts with Sections 145A and 145B, which govern the year of chargeability of interest income in certain contexts, and with Section 201, which addresses consequences of failure to deduct or deposit tax at source.

The 12 rulings

1. Bajaj Allianz General Insurance vs Bhanuben Bachubhai Chauhan

Bench: Gujarat High Court
Date: 25 September 2025
Sections engaged: 145A, 145B, 194A, 56
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Special Civil Application No. 5026 of 2018) was filed before the Gujarat High Court against orders dated 24.10.2017 and 25.10.2017 passed by the Tribunal below in M.A.C.P (Execution) Petition No. 192 of 2017 arising out of M.A.C.P. No. 527 of 2013. Per the source preview, the petitioner submitted that the entire awarded amount was deposited after deducting TDS amounting to Rs. 42,908/-, which was deducted because the claimants could not furnish their PAN details in time, and that the said detail was subsequently furnished before the learned Tribunal.

2. Karadia Maniben Parbatbhai vs State Of Gujarat

Bench: Gujarat High Court
Date: 16 September 2025
Sections engaged: 145, 145A, 145A(b), 194A, 197, 28, 34, 45(5), 56(2), 56(2)(viii), 57(iv)
Outcome: Outcome not specified in source
Procedural / substantive ground: Four connected writ petitions (R/Special Civil Application Nos. 11665, 11680, 11702, and 11910 of 2024) were taken up together for final hearing and disposal before the Gujarat High Court. Per the source preview, the petitioners challenged the action of the respondents in deducting income tax at the rate of 20% on the principal amount and 20% on the amount of interest awarded under Section 28 of the Land Acquisition Act, 1894, in connection with the acquisition of the petitioners' lands.

3. The Manager vs The Deputy Commissioner Of Labour

Bench: Madras High Court
Date: 24 September 2024
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P(MD) No. 6907 of 2024) was filed under Article 226 of the Constitution of India before the Madurai Bench of the Madras High Court, seeking a Writ of Mandamus directing the first respondent to accept a Demand Draft (D.D. No. 46779840, dated 07.02.2024) in respect of the award amount passed in E.C. 27 of 2023 and interest payable under the Workmen Compensation Act, with TDS deduction in accordance with Section 194A of the Income Tax Act, 1961. Per the source preview, the petitioner Insurance Company (M/s. New India Assurance Co. Ltd.) had been directed by the Deputy Commissioner of Labour and Workman Compensation Commissioner, Madurai, to pay a sum of Rs. 16,19,600/- to the claimants.

4. Samyak Projects Private Limited vs Ansal Housing Limited

Bench: Delhi High Court
Date: 14 May 2024
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (FAO(OS) 77/2023 & CM APPL. 34242/2023) was filed before the Delhi High Court under Section 10 of the Delhi High Court Act, 1966, impugning the order dated 26th April, 2023 passed by the learned Single Judge in CS(OS) No. 497/2018. Per the source preview, the appeal was limited to challenging the Single Judge's findings on the issue of limitation (paragraphs 29 to 38 of the impugned order), with the appellant contending that the issue of limitation involved mixed questions of fact and law and ought to have been left open for determination post-trial rather than decided at the stage of grant of leave to defend.

5. Mohamad Shakil Mohamad Nazir Siddiqui vs Kasambhai Hushenbhai Ghanchi

Bench: Gujarat High Court
Date: 30 April 2024
Sections engaged: 145A, 145A(b), 145B, 163A, 194A, 56
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Special Civil Application No. 2755 of 2024) was filed before the Gujarat High Court. Per the source preview, the petitioners submitted that the Motor Accident Claims Tribunal, Gir-Somnath, Veraval, by order dated 02.07.2022 in Execution Application No. 56 of 2018, declined to pay the amount which had been deducted as TDS, and that such order was erroneous in view of the judgment of the Division Bench of the Gujarat High Court in the case of Oriental Insurance Company Ltd. vs. Chief Commissioner of Income Tax (T.D.S.), reported in 2023 (2) GLR 1019; the insurance company's advocate in turn submitted that since the TDS amount had already been deducted and Form-16 had been sent to the claimant, the cause no longer survived.

6. The Magma Hdi General Insurance Co. Ltd vs Ilaben Pradipbhai Sherathiya

Bench: Gujarat High Court
Date: 26 April 2024
Sections engaged: 145A, 145B, 194A, 194A(3), 201, 56
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Special Civil Application No. 6919 of 2024) was filed under Article 226 of the Constitution of India before the Gujarat High Court. Per the source preview, the petitioner sought a writ to quash and set aside the order passed by the Motor Accident Claims Tribunal and Special Court at Gondal in MACP Ex No. 32/2023 dated 04/01/2024, and also sought an ad-interim ex-parte stay of the impugned order; the petition was heard as a matter arising in the context of TDS obligations on compensation payments.

7. The Divisional Manager vs The Joint Commissioner Of Labour

Bench: Madras High Court
Date: 27 September 2023
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(MD) No. 23538 of 2023) was filed under Article 226 of the Constitution of India before the Madurai Bench of the Madras High Court, seeking a Writ of Certiorarified Mandamus to call for and quash the impugned order passed by the first respondent in Ka.Mu.A. No. 40/2022, dated 28.12.2022, by which the first respondent refused to receive the cheques towards deposit of compensation. Per the source preview, the petitioner (National Insurance Company Limited) sought a further direction that the first respondent accept the deposit of compensation amount and interest payable in E.C No. 11 of 2019 by deducting TDS in accordance with Section 194A of the Income Tax Act, 1961.

8. Section Office vs The Joint Commissioner Of Labour

Bench: Madras High Court
Date: 13 September 2023
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(MD) No. 22343 of 2023) was filed under Article 226 of the Constitution of India before the Madurai Bench of the Madras High Court, seeking a Writ of Certiorarified Mandamus to call for and quash the impugned order passed by the Workmen Compensation Act Commissioner, Madurai, in Ka.Mu.A. 40 of 2023, dated 12.04.2023, by which the respondent refused to receive the cheques towards deposit of compensation. Per the source preview, the petitioner (Section Office, National Insurance Company Ltd.) sought a direction that the respondent accept the deposit of compensation amount and interest payable in EC No. 82 of 2016 by deducting TDS in accordance with Section 194A of the Income Tax Act, 1961.

9. The Branch Manager vs The Deputy Commissioner Of Labour

Bench: Madras High Court
Date: 21 August 2023
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(MD) No. 20209 of 2023) was filed under Article 226 of the Constitution of India before the Madurai Bench of the Madras High Court, seeking a Writ of Certiorarified Mandamus to call for and quash the impugned order passed by the Workmen Compensation Act Commissioner, Dindigul, in EC No. 119 of 2006, dated 19.06.2023, by which the respondent refused to receive the cheques towards deposit of compensation. Per the source preview, the petitioner (Branch Manager, National Insurance Company Ltd., Dindigul) sought a further direction that the respondent accept the deposit of compensation amount and interest payable in EC No. 119 of 2006 by deducting TDS in accordance with Section 194A of the Income Tax Act, 1961.

10. First Solar Power India Private Limited vs Assistant Commissioner Of Income Tax

Bench: Delhi High Court
Date: 26 May 2022
Sections engaged: 194A, 194J
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(C) 7436/2022 & CM APPLs. 22677-22678/2022) was filed before the Delhi High Court. Per the source preview, one of the issues involved in the matter related to interest income earned by the assessee under Section 194A from M/s. Anantapur Solar Parks Private Limited of INR 96,53,997/-, which the assessee reported under the head "Other Income – Interest income on unsecured loans" of INR 4,37,66,327/- as reflected in Note No. 21 of its financial statements; the matter also involved questions regarding time deposits with Yes Bank totalling INR 3,51,29,78,667/-.

11. Sainath Rajkumar Sarode And 8 Ors vs State Of Maharashtra And 6 Ors

Bench: Bombay High Court
Date: 18 August 2021
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (Writ Petition (L) No. 4804 of 2020) was filed before the Bombay High Court along with several interim applications. Per the source preview, the petitioners are individuals who between 2013 and 2016 entered into separate registered agreements with the respondent builder for purchase of various flats in a building known as Gaurav Discovery, proposed to be constructed at Village Malvani, Malad; the appeal was filed against the State of Maharashtra and other respondents, and Section 194A appears among the statutory provisions engaged in the proceedings.

12. The Branch Manager vs Vasanthi

Bench: Madras High Court
Date: 24 January 2020
Sections engaged: 194A
Outcome: Outcome not specified in source
Procedural / substantive ground: The Civil Revision Petition (CRP.PD(MD) No. 534 of 2020 & CMP(MD) No. 3376 of 2020) was filed under Article 227 of the Constitution of India before the Madurai Bench of the Madras High Court, directed against the order passed in EP No. 87 of 2019 in MCOP No. 67 of 2008 dated 24.01.2020 on the file of the Additional District Court cum Essential Commodities Court, Thanjavur. Per the source preview, the revision petitioner is the judgment debtor/second respondent (Branch Manager, ICICI Lombard Insurance Company, Thanjavur), and the respondents are the decree holders/claimants in MCOP No. 67 of 2008; the Additional District Judge had, after conducting an enquiry, passed an award on 15.02.2011.

Patterns across these 12 rulings

Recurring TDS-on-compensation dispute in insurance contexts. The most prominent pattern across this set of rulings is insurance companies approaching High Courts — particularly the Madurai Bench of the Madras High Court and the Gujarat High Court — to challenge orders by Labour Commissioners or Workmen Compensation Act Commissioners who refused to accept cheques or demand drafts for deposit of compensation amounts with TDS deducted under Section 194A. This recurring fact-pattern appears in cases 3, 7, 8, 9, and 12, as well as in the Gujarat motor accident cases 1, 5, and 6.
Section 194A engaged alongside Sections 145A and 145B in Gujarat HC matters. Several Gujarat High Court rulings in this set (cases 1, 5, and 6) engage Section 194A in conjunction with Sections 145A, 145B, and Section 56, suggesting that the year of chargeability and the head of income for interest components of compensation awards are live issues in that jurisdiction alongside the TDS obligation itself.
Land acquisition interest as a distinct sub-context. Case 2 (Karadia Maniben Parbatbhai vs State of Gujarat) involves a challenge to the rate of income-tax deduction applied to both the principal amount and the interest awarded under the Land Acquisition Act, 1894, engaging a wider cluster of statutory provisions. This sub-context — interest on land acquisition compensation — is distinct from the workmen's/motor accident compensation sub-context and engages additional provisions beyond Section 194A alone.
Income-tax assessment context (non-compensation). Cases 10 (First Solar Power India Private Limited vs ACIT) and 11 (Sainath Rajkumar Sarode vs State of Maharashtra) arise in contexts other than compensation award enforcement proceedings. Case 10 involves an income-tax assessment matter before the Delhi High Court where Section 194A is engaged in relation to interest income earned on unsecured loans, as reflected in the assessee's financial statements.
Outcomes uniformly not specified in source. Across all 12 cases in this compilation, the structured outcome direction field is recorded as "Outcome not specified in source." Researchers should treat this compilation as an entry-point index only and must retrieve the full judgment text from the source court portal to determine the operative holding, any directions issued, and whether the matter was disposed of or adjourned.

How to use this compilation

This compilation is organised as a first-pass research index. Each entry gives you the bench, date, sections engaged, and a brief procedural note drawn from the available source preview, allowing you to rapidly identify which rulings are likely relevant to a research question involving Section 194A. However, the source previews underlying this index are partial extracts and do not reproduce the full reasoning or operative order of any judgment. Before relying on any entry for any purpose, researchers must retrieve the complete judgment from the relevant court portal (such as the Madras High Court's JUDIS portal, the Gujarat High Court's official portal, or the Delhi High Court's official portal) or from indiankanoon.org, and read the full text of the order.

When conducting follow-up research, check whether the ruling has been challenged in a higher court, whether a stay has been granted, or whether the matter has been remanded. Several entries in this compilation are oral orders or interim orders, which may have been superseded by a final order in the same proceeding. Additionally, check whether any relevant CBDT circular, notification, or instruction has been issued that bears on the statutory question raised in the case, since administrative guidance can affect how courts and tribunals approach subsequent similar matters.

Finally, note that Section 194A operates at the intersection of multiple provisions — including Sections 145A, 145B, 56, 197, and 201 — and the applicable sub-section and exemption threshold are fact-specific. Cases arising in the compensation-award context (workmen's compensation, motor accident claims, land acquisition) engage distinct factual and statutory frameworks compared to cases arising in the corporate income-tax assessment context. Researchers should segregate these sub-categories when building arguments or drafting submissions.

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 194A TDS on Interest: 12 High Court Rulings (2020–2025)