Compliance with High Court Stay Negates Assessee in Default Status and Interest for Non-Deduction of TDS on Foreign Travel LTC

Ashwani Kumar — Fri, 21 Aug 2026 07:54:24 +0000

Issue

Whether an employer-deductor can be treated as an “assessee in default” under Section 201(1) and charged interest under Section 201(1A) for non-deduction of tax at source under Section 192 on Leave Travel Concession/Leave Fair Concession (LTC/LFC) payments involving foreign travel, when operating under binding interim directions of the High Court.

Facts

The assessee-deductor disbursed LTC/LFC payments to its employees for travel that included foreign destinations during Assessment Years 2016-17 and 2017-18.
During the relevant period, the assessee operated under binding interim directions issued by the Hon’ble Madras High Court concerning the tax treatment and guidelines of LTC/LFC schemes involving foreign travel.
Pursuant to and in compliance with these judicial directives, the assessee did not deduct tax at source (TDS) under Section 192 on such LTC/LFC reimbursements.
The Assessing Officer treated the deductor as an “assessee in default” under Section 201(1) for failing to deduct tax on foreign travel reimbursements and levied interest under Section 201(1A).

Decision

Decided in favor of the assessee.
The tribunal held that because the assessee-deductor was operating under binding interim orders of the Hon’ble Madras High Court during the relevant period, it was legally constrained from deducting tax at source on the LTC/LFC payments involving foreign travel.
Consequently, the assessee could not be treated as an “assessee in default” under Section 201(1), and no statutory interest was leviable under Section 201(1A).

Key Takeaways

Effect of Judicial Mandate: Action or non-action taken in strict compliance with binding interim orders of a High Court shields an employer from being penalized as an “assessee in default.”
Bona Fide Legal Obligation: When non-deduction of TDS arises from adherence to judicial directions rather than deliberate non-compliance, statutory default provisions under Section 201(1) do not apply.
Deletion of Interest Levy: Where the primary finding of default under Section 201(1) is set aside due to judicial stays, interest charged under Section 201(1A) automatically becomes unsustainable and must be deleted.

IN THE ITAT RAJKOT BENCH ‘SMC’

State Bank of India

Income-tax Officer, TDS

Dr. Arjun Lal Saini, Accountant Member

IT Appeal Nos. 161, 178, 190, 281, 328 & 343 (Rjt) of 2026
[Assessment years 2016-17 and 2017-18]

JULY 31, 2026

Dinesh Nair and Lokesh Karia, Ld. ARs for the Appellant. Abhimanyu Singh Yadav, Ld. Sr. DR for the Respondent.

ORDER

1. Captioned six appeals filed by different assessees, pertaining to assessment year 2016-17 and 2017-18, are directed against the separate orders passed by the Commissioner of Income Tax (Appeals), which in turn arise out of separate assessment orders passed by the Assessing Officer (in short ‘AO’) u/s.201(1) and 201(1A) of the Income Tax Act, 1961.

2. Since, the issue involved in all these appeals are common and identical therefore these appeals have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity. The grounds of appeal as well as facts narrated in ITA No.343/Rjt/2026 for the assessment year 2017-18 have been taken into consideration for deciding these appeals en masse.

3. The grounds of appeal raised by the assessee in lead case, in ITA No.343/Rjt/2026 are as follows:

The Learned Commissioner of Income-tax [Appeals) (“CIT(A)”) erred in confirming the order of the Assessing Officer (“AO”) holding the appellant to be an assessee in default for failing to deduct tax at source under section 192 of the Income-tax Act, 1961 (the Act).

The CIT(A) erred in not appreciating that the Appellant had issued e-Circular no. CDO/P&HRD-PM/7/2014-15 dated 15th April 2014 stating that the employees shall not be entitled to visit overseas countries/ centers as part of leave travel concession (“LTC”) which Circular was challenged by the All India State Bank Officers Federation & Ors, before the Madras High Court by way of a writ petition (WP no. 11991 of 2014) and that the Madras High Court had vide its order dated 25th April 2014 granted interim stay of the Circular.

The CIT(A) further erred in not appreciating that tax was not deducted at source by the Appellant on the LTC paid to its employees during the year under consideration in view of the specific interim directions issued by the Hon’ble Madras High Court in its order dated 16th February 2015 by which the Court held that the LTC paid or reimbursed would not amount to income and that no tax was to be deducted thereon. The CIT(A) ought to have appreciated that if the LTC was not to be treated as income of the employees as per the order of the Hon’ble Madras High Court, the same even otherwise would not require withholding of tax under section 192 of the Act.

The CIT(A) further erred in not appreciating that the Madras High Court vide its said order dated 16th February 2015 having directed the Appellant not to deduct at source on LTC had further stated that if the writ petition challenging the Circular was dismissed, the employees would be liable to pay tax on the LTC amount paid by the Appellant and, therefore, the CIT(A) ought to have quashed the order of the AO holding the Appellant to be an assessee in default.

The CIT(A) erred in not quashing the order of the AO holding the Appellant to be an assessee in default for the reason that the Appellant, even if it wanted to, could not have deducted tax at source on LTC paid during the year under consideration in view of the orders of the Hon’ble Madras High Court till the time they were in force as acting contrary to the orders of the Hon’ble Court would have amounted to contempt of Court.

The CIT(A) erred in not following the judgment of the Hon’ble Kerala High Court in State Bank of India v. CIT (ITA no. 45 of 2025 ) where the Hon’ble Court after considering the above set of facts held that the Appellant was justified in not deducting tax at source in view of the interim directions issued by the Madras High Court asking the Appellant not to deduct tax at source.

The CIT(A) erred in observing that the legal obligation to deduct tax was reinstated once the interim order passed by the Hon’ble Madras High Court was vacated without appreciating that the order of the Single Judge of the Hon’ble Madras High Court was challenged before the Division bench and later the Division bench’s order before the Hon’ble Supreme Court and that the Hon’ble Supreme Court in SLP(C) no. 16734 of 2023 has ordered the Appellant bank from not making any recoveries from its employees during the pendency of the petition.

Without prejudice to above grounds, the CIT(A) erred in not holding that the Appellant could not have been deemed to be an assessee in default under section 201(1) of the Act if the employee had furnished the return of income, taken into account such sum for computing income and paid the tax due on income declared by the employee.

4. Brief facts qua the issue are that in the instant case, information was received from the Deputy Commissioner of Income-tax, TDS Circle-2(2) Mumbai that during the financial year 2016-17 (relevant to AY 2017-18), the deductor, has paid Leave Fare Concession (LFC), which includes foreign travel, to the employees without deducting tax on such payments as required u/s. 192(1) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), which leads violation of provisions of sections 192(1) of the Act and making the assessee liable for default u/s 201(1) & 201(1A) r.w.s. 192(1) of the Act. The Hon’ble Supreme Court in its judgment (Civil Appeal No.8181 of 2022 dated 04/11/2022/State Bank of India v. Asstt. CIT (SC)/[2022] 449 ITR 192 (SC)) has held that:

“Leave Travel Concession (LTC)/LFC is not for foreign travel and is meant for travel within India. The moment employee undertake travel with a foreign leg, it is not a travel within India and hence not covered under the provisions of Section 10(5) of the Income Tax Act. The court dismissed the appeal filed by State Bank of India against the Delhi High Court judgment which held that the amount received by the SBI employees towards their LTC claims is not liable for the exemption as these employees had visited foreign. The Revenue had held SBI to be an “assessee in default”, for not deducting the tax at source of its employees”.

In view of the above, in respect of the proceedings u/s 201(1)/201(1A) of the Income-Tax Act, 1961 for F.Y.2016-17, a notice u/s 201(1)/201(1A) of the Income-Tax Act, 1961 was issued to the assessee, electronically on the ITBA portal on 30.06.2023 which was served upon the assessee online. Further, a reminder was also issued on 20.10.2023, seeking required details. However, the AO made addition holding as under:

“7. In view of the discussion made in above paras and duly perusing the details available on record, it is seen that the deductor has failed to discharge its liability under chapter XVIIB of the Act to the tune of the amount worked out as follows during the F.Y.2016-17 i.e. AY 2017-18. Further, vide above-mentioned show cause notices, the deduct was also show caused as to why the interest should not be charged u/s. 201(1A) of the Act on the default amount @ 1% per month or part of the month for the period from date of payment made to the date of Order u/s 201(1) of the Act as default continues. In response, the deductor failed to submit any justification before the undersigned till the date that why the interest should not be levied in its case u/s. 201(1A) of the Act for the year under consideration.

In view of the above facts, as per the relevant provisions of the Act, the assessee is treated as assessee in default u/s 201(1) r.w.s. 201(1A) of the Income-tax Act, 1961. The liability for tax/interest u/s 201(1)/201(1A) from April, 2016 to October, 2023 is worked out as under:

Accordingly, the assessee is liable to pay tax/interest of Rs.2,09,340/- u/s 201(1)/201(1A) of the Income-tax Act, 1961.

5. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has confirmed the action of Assessing Officer, observing as follows:

“13. The contention of the Appellant that there is no specific bar under Section 10(5) for a foreign travel and therefore a foreign journey can be availed as long as the starting and destination points remain within India is also without merits. LTC is for travel within India, from one place in India to another place in India. There should be no ambiguity on this.

14. The second argument urged by the appellant that payments made to these employees was of the shortest route of their actual travel cannot be accepted either. It has already been clarified above, that in view of the provisions of the Act, the moment employees undertake travel with a foreign leg, it is not a travel within India and hence not covered under the provisions of Section 10(5) of the Act.

15. A foreign travel also frustrates the basic purpose of LTC. The basic objective of the LTC scheme was to familiarise a civil servant or a Government employee to gain some perspective of Indian culture by traveling in this vast country. It is for this reason that the 6th Pay Commission rejected the demand of paying cash compensation in lieu of LTC and also rejected the demand of foreign travel. In para 4.3.4 of the 6th Pay Commission Report dated March 2008 this is what was said:

“4.3.4. The demand for allowing travel abroad at least once in the entire career under the scheme is not in consonance with the basic objective of the scheme. The Government employee cannot gain any perspective of the Indian culture by traveling abroad. Besides, the attendant cost in foreign travel would also make the expenditure under this scheme much higher. The Commission is, therefore, not inclined to concede the demand to allow foreign travel under LTC.”

This is also an objection of the Revenue which has been raised in its counter affidavit filed by respondent no. 1-Assistant Commission of Income Tax wherein the Revenue has asserted that the provision for LTC was introduced to motivate employees and encourage its employees towards tourism in India and it is for this reason that reimbursement of LTC was exempted. There was no intention of legislature to allow the employees to travel abroad in the garb of LTC available by virtue of Section 10(5) of the Act. Therefore, the Revenue has a valid objection (apart from other objections which are clearly violative of the Statute), that the intention and purpose of the scheme is also violated in the garb of tour within India, foreign travel is being availed.

16. The aforementioned order passed by the CIT(A) has rightly held that the obligation of deducting tax is distinct from payment of tax. The appellant cannot claim ignorance about the travel plans of its employees as during settlement of LTC Bills the complete facts are available before the assessee about the details of their employees’ travels. Therefore, it cannot be a case of bona fide mistake, as all the relevant facts were before the Assessee, employer and he was therefore fully in a position to calculate the ‘estimated income’ of its employees. The contention of Shri K.V. Vishwanathan, learned senior advocate that there may be a bona fide mistake by the assessee-employer in calculating the ‘estimated income’ cannot be accepted since all the relevant documents and material were before the assessee- employer at the relevant time and the assessee- employer therefore ought to have applied his mind and deducted tax at source as it was his statutory duty, under Section 192(1) of the Act.”

6. Aggrieved by the order of the Ld. CIT(A), the assessee is in further appeal before this Tribunal.

7. Learned Counsel for the assessee submitted written submission before me, which are reproduced below:

(1) The LTC was paid to one employee by the branch i.e. to Mr. Mukesh Pandit, amounting to Rs.4,94,480/- on dated 30-09-2016 and the corresponding tax and interest demanded by Income Tax Department thereon is Rs.1,48,344/- (u/s.201(1)) and 1,26,092/- (u/s.201(1A)) respectively. Hence, total tax liability raised by ITD is Rs.2,74,436/-. Said foreign travel was done by employee to foreign countries namely Italy, France, Switzerland and Austria.

(2) The contention of the assessee has consistently been that during the year under consideration, it was bound by the interim orders passed by the Hon’ble Madras High Court in W.P. No.11991 of 2014, wherein vide order dated 16.02.2015 it was specifically clarified that the LFC payments would not amount to income so as to enable deduction of tax at source and further that if the writ petition was ultimately dismissed, the employees would be liable to pay tax. The assessee has submitted that in view of such binding judicial directions, it could not have deducted tax at source and any such deduction would have amounted to disobedience of the order of the Hon’ble High Court. The copy of said judicial pronouncements were attached in original written submission (Appeal) before your honour’s bench.

(3) Our client, SBI has considerable merit in the aforesaid contention. The interim directions of the Hon’ble Madras High Court were in force during the relevant previous year and the assessee, being a party (respondent) to the proceedings, was duty bound to comply with the same. The obligation under section 192 of the Act to deduct tax at source cannot be read in isolation and must yield to binding judicial orders. Therefore, the failure to deduct tax in such circumstances cannot be equated with a default contemplated under section 201(1) of the Act.

(4) We further state that an identical issue has been considered by the Co-ordinate Bench of the Tribunal in the case of State Bank of India in ITA No.514/Agr/2024, ITA No. 453 & 454/Ahd/2026 dated 26-03-2026 and ITA No.339/Ahd/2026 dated 09-042026, wherein after considering the decision of the Hon’ble Supreme Court as well as the interim orders of the Hon’ble Madras High Court, ITAT held that the assessee bank could not be treated as an assessee in default since it was bound to follow the interim directions of the Hon’ble High Court. The Tribunal categorically observed that the assessee had no option but to comply with the orders of the Hon’ble High Court and non-deduction of tax in such circumstances could not invite the rigours of section 201(1) and 201(1A) of the Act. The copy of judgements of said Tribunal Orders are attached herewith.

(5) More importantly, the Hon’ble Kerala High Court in ITA No.45 of 2025 (order dated 18th November 2025) has examined this issue in detail and has held in favour of the assessee. The relevant findings of the Hon’ble High Court, which have a direct bearing on the said issue, are reproduced below for ready reference:

“The interim order granted by this Court is explained to the effect that any amount paid to the petitioner towards LTC or re-imbursement of LTC pursuant to the impugned order would not amount to income so as to enable the Bank to deduct tax at source. It is made clear that if the writ petition is dismissed, the employees are liable to pay tax on the amount paid by Bank.”

“It is only when the appellant-assessee, after having a liability to deduct tax, fails to do so, the question of invoking Section 201 of the Act and treating it as an ‘assessee in default’ could be arrived. Here, the Hon’ble Madras High Court found, prima facie, that the amount paid would not be the income of a payee so as to deduct tax. Therefore, the provisions of Section 201(1) of the Act are not attracted to the case at hand.”

“The appellant-assessee was under an obligation not to deduct tax at source and therefore, the assessee can not be held to be assessee in-default for non-deduction of tax at source on impugned LFC payments.” The Hon’ble Kerala High Court has thus clearly held that where the assessee was restrained by judicial orders from deducting tax at source, the provisions of section 201 of the Act cannot be invoked and the assessee cannot be treated as an assessee in default. The copy of said judgement of Kerala High Court was attached by us in the original submission (Appeal) furnished to your honour’s bench.

(6) In the present case also, the facts are materially identical. The assessee was operating under the binding interim directions of the Hon’ble Madras High Court during the relevant period and therefore could not have deducted tax at source. The subsequent decision of the Hon’ble Supreme Court, though settling the issue on merits, does not retrospectively fasten liability under section 201(1) of the Act for a period during which the assessee was acting in compliance with judicial orders.

(7) We also submit that the scheme of section 201 of the Act itself contemplates that a person can be treated as an assessee in default only when there is a failure to deduct tax in spite of a legal obligation to do so. In the present case, such legal obligation stood eclipsed by the interim directions of the Hon’ble Madras High Court.

In respect of the above explanation furnished by us and respectfully following the decision of the Hon’ble Kerala High Court in ITA No.45 of 2025 and the decision of the Co-ordinate Bench in ITA No.514/Agr/2024, ITA No. 453 & 454/Ahd/2026 dated 26-03-2026 and ITA No.339/Ahd/2026 dated 09-04-2026, we submit that the assessee should not be treated as an assessee in default under section 201(1) of the Act for the impugned period. Consequently, we additionally submit that the interest charged under section 201(1A) also should not be survived”.

8. On the other hand, Ld. DR for the revenue also submitted written submission, which are reproduced below:

“The issue raised in the present appeal is no longer res integra and stands conclusively settled by the Hon’ble Supreme Court in State Bank of India v. Assistant Commissioner of Income Tax, Civil Appeal No. 8181 of 2022, decided on 04.11.2022.

1. Statutory Obligation under Section 192

The Hon’ble Supreme Court has categorically held that the obligation to deduct tax at source under Section 192 is a statutory duty of the employer. The employer is required to compute the “estimated income” of the employee based on material available at the time of payment

2. Distinct Nature of Deduction and Payment of Tax

The Court clarified that the obligation to deduct tax is distinct from the ultimate tax liability of the employee. Failure to deduct TDS, where legally required, renders the employer an “assessee in default” under Section 201

3. No Defence of Bona Fide Mistake Where Facts Are Available

It has been expressly held that where all relevant documents and facts are available with the employer, the plea of bona fide mistake is not sustainable.

The employer is expected to apply its mind and comply strictly with statutory provisions.

4. Strict Interpretation of Exemption Provisions.

The Supreme Court reaffirmed that exemption provisions (such as Section 10(5) in that case) must be strictly construed, and any deviation from statutory conditions disentitles the benefit.

Application to Present Case

In view of the authoritative pronouncement of the Hon’ble Supreme Court:

The statutory obligation of TDS cannot be diluted by interpretational latitude.

Once the material on record indicates that the conditions for exemption/deduction are not satisfied, non-deduction automatically attracts consequences under Section 201.

The plea of ambiguity, administrative practice, or bona fide belief is legally untenable where statutory requirements are clear.

Accordingly, the issue is fully covered by the judgment of the Hon’ble Supreme Court. The matter is settled law and does not give rise to any debatable question. The appeal of the assessee is devoid of merit and deserves to be dismissed”.

9. I have heard, both the parties and perused the material available on record. I note that stay order of the Hon’ble Madras High Court was started from 25.03.2014 and it was up to 24.03.2022, therefore all the appeals of these different assessees, fall under this period, where the State Bank of India (employer), supposed to obey the order of the Hon’ble Madras High Court and therefore, SBI-employer did not deduct the TDS on LTC. Therefore, taking into account these facts, I find that the issue is squarely covered, in favour of the assessee by the judgment of the Coordinate Bench of ITAT Ahmedabad in the case of State Bank of India Bhavnagar Para Branch, in ITA No.453 & 454/Ahd/2026, vide order dated 26.03.2026State Bank of India Bhavnagar Para Branch v. ITO, TDS [2026] (Ahmedabad – Trib.)/ , wherein it was held as follows:

“11. We have heard the rival contentions and perused the material available on record.

12. At the outset, we note that the issue on merits regarding allowability of exemption under section 10(5) of the Act in cases where the journey involves a foreign leg now stands concluded against the assessee by the judgment of the Hon’ble Supreme Court dated 04.11.2022. There is no dispute on this legal position and the same is duly acknowledged. However, the limited controversy before us is whether, in the peculiar facts of the present case, the assessee can be treated as an “assessee in default” under section 201(1) of the Act for non-deduction of tax at source during the relevant period.

13. The contention of the assessee has consistently been that during the year under consideration, it was bound by the interim orders passed by the Hon’ble Madras High Court in All India State Bank Officers Federation v. State Bank of India [2022] 447 ITR 559 (Madras) /W.P. No.11991 of 2014, wherein vide order dated 16.02.2015 it was specifically clarified that the LFC/LTC payments would not amount to income so as to enable deduction of tax at source and further that if the writ petition was ultimately dismissed, the employees would be liable to pay tax. The assessee has submitted that in view of such binding judicial directions, it could not have deducted tax at source and any such deduction would have amounted to disobedience of the order of the Hon’ble High Court.

14. We find considerable merit in the aforesaid contention of the assessee. The interim directions of the Hon’ble Madras High Court were in force during the relevant previous year and the assessee, being a party to the proceedings, was duty bound to comply with the same. The obligation under section 192 of the Act to deduct tax at source cannot be read in isolation and must yield to binding judicial orders. Therefore, the failure to deduct tax in such circumstances cannot be equated with a default contemplated under section 201(1) of the Act.

15. We further find that an identical issue has been considered by the Co-ordinate Bench of the Tribunal in the case of State Bank of India v. CIT (Appeals) (Agra – Trib.) /ITA No.514/Agr/2024, wherein after considering the decision of the Hon’ble Supreme Court as well as the interim orders of the Hon’ble Madras High Court, ITAT held that the assessee bank could not be treated as an assessee in default since it was bound to follow the interim directions of the Hon’ble High Court. The Tribunal categorically observed that the assessee had no option but to comply with the orders of the Hon’ble High Court and non-deduction of tax in such circumstances could not invite the rigours of section 201(1) and 201(1A) of the Act.

16. More importantly, the Hon’ble Kerala High Court in State Bank of India v. CIT (Kerala) /ITA No. 45 of 2025 (order dated 18th November 2025) has examined this issue in detail and has held in favour of the assessee. The relevant findings of the Hon’ble High Court, which have a direct bearing on the issue before us, are reproduced below for ready reference:

“It is only when the appellant-assessee, after having a liability to deduct tax, fails to do so, the question of invoking Section 201 of the Act and treating it as an ‘assessee in default’ arises. Here, the Madras High Court found, prima facie, that the amount paid would not be the income of a payee so as to deduct tax. Therefore, we are of the opinion that the provisions of Section 201(1) of the Act are not attracted to the case at hand. ”

“The appellant-assessee was under an obligation not to deduct tax at source and therefore, the assessee could not be held to be assessee in-default for nondeduction of tax at source on impugned LFC payments. ”

17. The Hon’ble High Court has thus clearly held that where the assessee was restrained by judicial orders from deducting tax at source, the provisions of section 201 of the Act cannot be invoked and the assessee cannot be treated as an assessee in default.

18. In the present case also, the facts are materially identical. The assessee was operating under the binding interim directions of the Hon’ble Madras High Court during the relevant period and therefore could not have deducted tax at source. The subsequent decision of the Hon’ble Supreme Court, though settling the issue on merits, cannot retrospectively fasten liability under section 201(1) of the Act for a period during which the assessee was acting in compliance with judicial orders.

19. We also find force in the argument of the assessee that the scheme of section 201 of the Act itself contemplates that a person can be treated as an assessee in default only when there is a failure to deduct tax in spite of a legal obligation to do so. In the present case, such legal obligation stood eclipsed by the interim directions of the Hon’ble High Court.

20. In view of the above discussion, respectfully following the decision of the Hon’ble Kerala High Court in State Bank of India (supra) and the decision of the Co-ordinate Bench in ITA No.514/Agr/2024, we hold that the assessee cannot be treated as an assessee in default under section 201(1) of the Act for the impugned period. Consequently, the interest charged under section 201(1A) also does not survive.

21. Accordingly, we direct the Assessing Officer to delete the demand raised under section 201(1) and 201(1A) of the Act.

22. In the result, both the appeals of the assessee are allowed.

10. From the above binding decision, it is vivid that the assessee was operating under the binding interim directions of the Hon’ble Madras High Court (supra) during the relevant period and therefore could not have deducted tax at source. The subsequent decision of the Hon’ble Supreme Court, though settling the issue on merits, does not retrospectively fasten liability under section 201(1) of the Act for a period during which the assessee was acting in compliance with judicial orders. The interim directions of the Hon’ble Madras High Court were in force during the relevant previous year and the assessee, being a party (respondent) to the proceedings, was duty bound to comply with the same. The obligation under section 192 of the Act to deduct tax at source cannot be read in isolation and must yield to binding judicial orders. Therefore, the failure to deduct tax in such circumstances cannot be equated with a default contemplated under section 201(1) of the Act. Therefore, respectfully following the judgment of the Co-ordinate Bench of ITAT Ahmedabad in the case of State Bank of India, Bhavnagar (supra), on the same and identical facts, I allow the appeal of the assessee.

11. Since, I have adjudicated the issue by taking the lead case in ITA No. 343/Rjt/2026 for assessment year 2017-18 and the facts and grounds of appeal in other assessee’s case are similar and identical, therefore the observations and the decision rendered in ITA No.343/Rjt/2026 are applicable mutatis and mutandis to other appeals also that is, in ITA No.161/Rjt/2026, ITA No.178/Rjt/2026, 190/Rjt/2026, 281/Rjt/2026 and 328/Rjt/2026.

12. In the combined result, all appeals filed by the different assessees, are allowed.

IN THE ITAT RAJKOT BENCH Archives - Tax Heal

Compliance with High Court Stay Negates Assessee in Default Status and Interest for Non-Deduction of TDS on Foreign Travel LTC