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TMI Blog2015 (1) TMI 473X X X X Extracts X X X X X X X X Extracts X X X X ..... gazette? Held that:- Once the notification stands issued, it is not the requirement of the Act for the assessee to either apply or seek exemption from the Authorities under the Act or the Central Government. Expression “reasons to be recorded in writing” are in reference to the stage preceding issuance of notification by the Central Government. Reasons have to be that of the Central Government ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... only be granted to the assessee after the Central Government issued a notification in this behalf in the official gazette? 2. Genesis of the dispute emanates with the alleged non-compliance of statutory provisions of Section 194A (1) of the Income Tax Act, 1961 (hereinafter referred to as the Act) by the assessee/respondent herein. M/s Biotech Biobusiness and HP SITEG, wholly financed and con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tate Bank of Patiala. 5. For the purposes of adjudication of the present appeal, relevant provisions of the Act, are reproduced as under:- 194A. (1) Any person, not being an individual or a Hindu undivided family, who is responsible for paying to a resident ay income by way of interest other than income [by way of interest on securities], shall, at the time of credit of such income to the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dy including a Society registered under the Societies Registration Act, 1860 (XXI of 1860) financed wholly by the Government. 8. Now the language of Section 194A of the Act is simple, unambiguous and evidently clear. The Central Government has issued notification, specifically exempting, inter alia, Societies which are wholly financed by the Government, thus making the provisions of Section 1 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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