C O M M O N J U D G M E N T

(Judgment of the Court was made by DR.ANITA SUMANTH, J.)

W.P.No.18138 of 2020 has been filed by Madurai District Co- operative Central Bank Limited seeking a declaration that Section 194N of the Income Tax Act, 1961 (in short ‘Act’), inserted vide Finance Act, 2019 is illegal, arbitrary, infringes the fundamental rights under Article 14 and 19(i)(g) and is unenforceable and unconstitutional. The batch of Writ Appeals challenges an order passed by the Writ Court disposing Writ Petitions filed by the District Central Cooperative Banks challenging orders passed u/s 201/201(1A) of the Act.

2. Since the vires of the Section has been challenged, it would be appropriate to deal with the Writ Petition first before proceeding to deal with the batch of Writ Appeals. The submissions of the petitioner, as advanced by Mr.R.Sivaraman, learned counsel appearing for the petitioner are as follows.

3. The petitioner holds a licence to carry on banking business issued by the Reserve Bank of India (RBI). It maintains the accounts of 254 Cooperative Societies (both savings as well as current accounts). Those Societies are Primary Agricultural Cooperative Credit Societies (PACCS)