Judicial Constraint Doctrine

This matter arises from orders passed by the Income Tax Appellate Tribunal, Ahmedabad Bench, in ITA Nos. 453 & 454/Ahd/2026 for Assessment Year 2016–17, pronounced on 26.03.2026, involving State Bank of India, Bhavnagar Para Branch. 

The core issue is not the taxability of Leave Fare Concession (LFC) involving foreign travel, already settled by the Supreme Court, but whether the bank could be treated as an “assessee in default” under Section 201(1) for non-deduction of TDS during a period when binding interim directions of the Madras High Court prohibited such deduction. 

The Tribunal holds that compliance with judicial orders overrides withholding obligations, thereby negating default and consequential interest liability.