Income-tax Act, 1961 · Chapter XVII: Collection and Recovery of Tax · B.—Deduction at source
Section 196: Interest or dividend or other sums payable to Government, Reserve Bank or certain Corporations
The Income-tax Act, 1961 was repealed by the Income-tax Act, 2025 from 1 April 2026. The text is kept here because the judgments below apply it.
In plain words
This section stops people from deducting tax at source when paying money to specific entities. It applies to the Government, the Reserve Bank of India, certain corporations exempt from income tax, and specific Mutual Funds. If you pay interest, dividends, or other income to these groups, you do not withhold tax from the payment.
- No tax deduction is required for sums payable to the Government.
- No tax deduction is required for sums payable to the Reserve Bank of India.
- No tax deduction is required for corporations established by a Central Act that are exempt from income tax.
- No tax deduction is required for Mutual Funds specified under clause (23D) of section 10.
- For Mutual Funds, the payment must be interest or dividend on securities or shares they own or have full beneficial interest in.
- For Mutual Funds, the payment can also be any other income accruing or arising to it.
Example: If a company pays interest to the Reserve Bank of India, it does not deduct tax from that payment.
A simplified explanation, prepared with AI assistance from the official text below and checked automatically against it for numbers and cross-references. The official text is the law and prevails over this summary. Not legal advice.
Official text
Notwithstanding anything contained in the foregoing provisions of this Chapter, no deduction of tax shall be made by any person from any sums payable to—
(i) the Government, or
(ii) the Reserve Bank of India, or
(iii) a corporation established by or under a Central Act which is, under any law for the time being in force, exempt from income-tax on its income, or
(iv) a Mutual Fund specified under clause (23D) of section 10, where such sum is payable to it by way of interest or dividend in respect of any securities or shares owned by it or in which it has full beneficial interest, or any other income accruing or arising to it.]
Source: India Code (Legislative Department), the text of the Act as it stood before its repeal. Words in square brackets [ ] were inserted or substituted by later amending Acts, and *** marks words omitted by an amendment. The amendment footnotes are not reproduced here. Official text on India Code.
Supreme Court judgments citing the section 196
- Countrywide Promoters Pvt. Ltd v. Commissioner of Income Tax (Tds)-1, Delhi & Anr
- Jagran Developers Pvt. Ltd v. National Faceless Assessment Centre
- M/S Ramprastha Estates Pvt. Ltd v. Union of India & Ors
- M/S Omaxe Ltd v. Deputy Commissioner of Income Tax & Ors
- Natureville Promoters Private Limited v. Union of India & Ors
- Ansal Properties and Infrastructure Ltd v. Dy Commissioner of Income Tax Circle 73(1)
- Chintels India Pvt Ltd v. Deputy Commissioner of Income Tax Circle 73(1), Delhi
- M/S Florentine Estates of India Ltd v. Union of India & Ors
- Raheja Developers Limited v. Assistant Commissioner of Income Tax & Ors
- One Height Colonizers Pvt. Ltd v. Income Tax Officer, Ward 76(2) & Anr
- M/S Vipul Sez Developers Pvt. Ltd v. Union of India & Ors
- Jagran Developers Pvt. Ltd v. National Faceless Assessment Centre
- Raheja Developers Limited v. Assistant Commissioner of Income Tax Circle 78(1) Delhi and Ors
- M/S One Point Reality Private Limited v. Income Tax Officer Ward 76(2), Delhi
- M/S Alpha Corp Development Pvt Ltd v. Assistant Commisisoner of Income Tax & Anr
- One Point Reality Pvt Ltd v. Income Tax Officer, Ward 76(2) & Anr
- M/S One Point Reality Private Limited v. Income Tax Officer Ward 76(2), Delhi
- M/S Ramprastha Estates Pvt. Ltd v. Union of India & Ors
- Rps Infrastructure Limited v. Assistant Commissioner of Income Tax, Circle-78-1 & Anr
- Brahma City Private Limited v. Income Tax Officer Ward 73 3 Delhi & Anr
- M/S Vipul Sez Developers Pvt. Ltd v. Union of India & Ors
- M/S Alpha Corp Development Pvt. Ltd v. Income Tax Officer & Anr
- M/S Ts Realtech Pvt. Ltd v. Union of India & Ors
- Puri Constructions Private Limited v. Additional Commissioner of & Ors
- Nova Realtors Pvt Ltd v. Income Tax Officer
- Rps Infrastructure Limited v. Assistant Commissioner of Income Tax, Circle-78, Tds-02
- M/S Puri Construction Limited v. Union of India & Ors
- Raheja Developers Limited v. Assistant Commissioner of Income Tax & Ors
- Rps Infrastructure Limited v. Assistant Commissioner of Income Tax, Circle-78-1 & Anr
- Benchmark Infotech Pvt Ltd v. Income Tax Officer Tds Ward73(3)
- M/S Florentine Estates of India Ltd v. Union of India & Ors
- Active Promoters Private Limited v. Income Tax Officer Ward 73(1), Delhi