JUDGMENT : Devan Ramachandran, J. The Income Tax Act, 1961 (the ‘Act’ for short), through Section 194A thereof, enjoins that “(1) Any person, not being an individual or a Hindu undivided family, who is responsible for paying to a resident, any 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 account of the payee, or at the time of payment thereof in cash, or by issuing of cheque or draft or by any other mode, whichever is earlier, deduct income tax thereon at the rates in force.” 2. After mandating thus, Section 194A (3) of the “Act” exempts certain categories from the afore obligation. 3. One of the categories so mentioned, are Co operative Societies registered under the Kerala Co operative Societies Act, (“KCS Act” for short); and the exemptions they enjoy are available in Sections 194A (3)(v) and 194A(3)(viia) of the ‘Act’. 4. Since the afore provisions will have to be read in its full, we extract them as under: Section 194A (3)(v): “to such income credited or [paid by a co-operative society (other than a co operative bank) to a member thereof or to such income credited or paid by a co operative society] to any other co operative society; [Explanation:- For the purposes of this clause, “co-operative bank” shall have the same meaning assigned to it in Part V of the Banking Regulation Act, 1949 (10 of 1949);] Section 194A (3)(viia): to such income credited or paid in respect of,— (a)deposits with a primary agricultural credit society or a primary credit society or a co-operative land mortgage bank or a co-operative land development bank; (b) deposits (other than time deposits made on or after the 1st day of July, 1995) with a Co-operative Society, other than a co-operative society or bank referred to in sub-clause (a), engaged in carrying on the business of banking;]” 5. The genesis of the controversy in these cases is in the fact that, the Finance Act, 2020 , added a proviso to Section 194A (3) to the following effect: [Provided that a co-operative society referred to in clause (v) or clause (viia) shall be liable to deduct income-tax in accordance with the provisions of sub-section (1), if- (a) the total sales, gross receipts or turnover of the co-operative society exceeds fifty crore rupees during the financial year immediately preceding the financial year in which the interest referred to in sub-section (1) is credited or paid; and (b) the amount of interest, or the aggregate of the amounts of such interest, credited or paid, or is likely to be credited or paid, during the financial year is more than [one lakh] rupees in case of payee being a senior citizen and [fifty thousand] rupees in any other case.] [Explanation 1.- For the purposes of clauses (i), (vii) and (viia), "time deposits" means deposits ([including] recurring deposits) repayable on the expiry of fixed periods. [Explanation 2.- For the purposes of this sub-section, "senior citizen" means an individual resident in India who is of the age of sixty years or more at any time during the relevant previous year.]] 6. This led the Revenue to issue notices to all Co-operative Societies which fall within the ambit of the afore proviso; and consequently, Societies which are members of the State Co-operative Bank and Urban Banks approached this Court through one set of Writ Petitions challenging it; while, certain Societies who are obligated as “deductor” under the afore scheme, impelled assail on the ground that they are being unnecessarily burdened. 7. In addition to the contentions raised, the Writ Petitioners in some of the cases also call into question the constitutionality of the afore extracted proviso; and all matters were thus heard together by the learned Single Judge, culminating in the impugned judgment. 8. The learned Single Judge dismissed all the Writ Petitions, granting imprimatur to the constitutional vires of the proviso; thus leaving the appellants no choice, but to file the afore appeals. 9. Though the fundamental and germane issues in these appeals are edificed on analogous legal and factual status, they require to be divided into batches/groups, going by the nature of the contentions before us. 10. 9. Though the fundamental and germane issues in these appeals are edificed on analogous legal and factual status, they require to be divided into batches/groups, going by the nature of the contentions before us. 10. We will hereinafter refer to the appeals in the batches mentioned above; for which, we append the list of the various appeals, so grouped, as a part of this judgment. 11. The first set of Writ Petitions are those filed by societies who are members of the State Cooperative Bank (“Kerala Bank”, as it is known) and the Urban Banks, who contend that, since they enjoy benefits under Section 80P(1), read with Section 80P(2)(d), of the “Act”, deduction of Tax at source by the said Banks is impermissible and illegal. 12. The 2nd batch of Writ Appeals have been filed by Societies which are “Deductors” and who fall within the ambit of the afore mentioned Section 194A (3)(v) and 194A(3)(viia) of the “Act”. Their imputation is that they have been unfairly and unnecessarily burdened with the obligation of making deductions of tax at source, when such a rigor has not been placed against the “Kerala Bank” - which is, by far, the biggest financial entity in the Co-operative Sector; or the Urban Banks, atleast qua its members which are Co-operative Societies. 13. The 3rd set of appeals are filed by the Tax Department, being aggrieved by a subsequent clarification added to the judgments by the learned Single Judge, that no action be taken against any society for not having deducted tax at source; and that such an obligation will operate against them only prospectively, namely subsequent to the date of the judgments. 14. As limpidly evident, under the sweep of Section 194A (3)(v) of the “Act”, any income credited by a Co-operative Society (other than a Co-operative Bank) to a member thereof; or to such income credited or paid by a Co-operative Society to another Cooperative Society, would stand exempted from the rigor of tax being deducted from it at source, notwithstanding Section 194A (1) thereof. 15. Similarly, as per Section 194A (3)(viia) of the “Act”, all income credited or paid in respect of deposits with Primary Agricultural Credit Society, or a Primary Credit Society, or a Co-operative Land Mortgage Bank, or a Co-operative Land Development Bank, also stand exempt from the onus of deductions of tax from it at source. 16. 15. Similarly, as per Section 194A (3)(viia) of the “Act”, all income credited or paid in respect of deposits with Primary Agricultural Credit Society, or a Primary Credit Society, or a Co-operative Land Mortgage Bank, or a Co-operative Land Development Bank, also stand exempt from the onus of deductions of tax from it at source. 16. This scenario was altered by the amendment brought in through the Finance Act, 2020 , when the impugned proviso was introduced, thus effectively restricting the above said exemption to certain type of societies alone, namely, those whose total savings/gross receipts/turnover does not exceed Rs.50 Crores in the year immediately preceding the Financial Year in which the interest referred to is credited or paid. It also stipulates that the exemption would continue only if the amount of interest, or the aggregate of such interest, credited or paid, or is likely to be credited or paid, during the Financial Year is not more than Rs.1 lakh in the case of a senior citizen, or Rs.50,000/- in any other. 17. The appellants in batches 1 and 2 appeals argue, inter alia, that the impugned proviso has been misinterpreted by the Tax Department, to render that even the State Co-operative Bank and Urban Banks are liable to deduct Tax at source from member Societies, when it is fully exempt to do so, going by the “Explanatory Note” to the Finance Act, 2015 , issued by the Central Board of Direct Taxes (CBDT). They argue that this “Explanatory Note” was conceded to before this Court in an earlier round of litigation, namely in The Thalapalam Service Co-operative Bank Ltd. v. The Central Board of Direct Taxes [WP(C) No.14895/2019] filed by another Co-operative Bank; and that it has been declared as under therein: “3. At the very outset, it might be noticed that in respect of the claim for exemption under Section 194A (3)(iii)(v), the revenue has fairly conceded that in as much as the Primary Agricultural Credit Societies are also Co-operative Societies, they would be entitled to the exemption under Section 194A (3)(iii)(v), whenever the income credited to their account is the interest income that arises from the deposits made by them with another Cooperative Society such as the District Co-operative Bank. In view of the said stand taken by the revenue in these writ petitions, the entitlement of the petitioners to the benefit of the exemption under 194A(3)(iii)(v) is found in their favour and the writ petitions that impugn the circulars issued by the various District Cooperative Banks based on the instructions of the Income Tax Department are hereby quashed. In the result, these writ petitions are disposed by declaring that, in the case of deposits made by the petitioner societies with the Cooperative Banks, they would be entitled to the benefit of exemption under Section 194A (3)(iii)(v) of the Income Tax Act and, in respect of the deposits made by the petitioner societies with the Treasury, they will not be entitled to the benefit of exemption under Section 194A (3)(iii)(a) of the Income Tax Act. The legality of the circulars and notices impugned in these writ petitions shall stand determined on the basis of the above declarations.” 18. Sri.Christopher Abraham, learned Standing Counsel for the Income Tax Department, however, in response, submitted that, going by a plain reading of Section 194A (3)(v), Co-operative Banks are not exempt from deducting tax from their members who are also Cooperative Societies; but conceded that Clause 42.7 of the Explanatory Note of the Finance Act, 2015 appears to provide for such. 19. To get a grip on the above rival submissions, a reading of Clause 42.7 of the Explanatory Note to the Finance Act, 2015 becomes vitally necessary, for which, it is reproduced as under: “Further, the existing exemption provided under section 194A(3)(v) of the Income-tax Act from deduction of tax from interest paid by a co-operative society to another co-operative society shall continue to apply to the co-operative bank and, therefore, a co-operative bank shall not be required to deduct tax from the payment of interest on time deposit to a depositor, being a co-operative society.” 20. Ex-facie from this Note, the above noted assertion of Sri.Christopher Abraham cannot obtain strength; and the exemption to Co-operative Banks from deducting tax at source on interest payable on ‘Time Deposits’ to a member-society is too obvious for contest. 21. Therefore, the acme question for our consideration is whether the impugned proviso has any relevance or bearing on Co-operative Banks. 22. 21. Therefore, the acme question for our consideration is whether the impugned proviso has any relevance or bearing on Co-operative Banks. 22. As mentioned above and solely to reiterate, Section 194A (3)(v) of the “Act” stipulates that the exemption offered therein would not apply to a Cooperative Bank. This is without doubt and is fully admitted. Thereafter, the explanation to it clarifies that a Co-operative Bank shall have the same meaning assigned to it in Part V of the Banking Regulation Act, 1949 . (“BR Act”).It is also beyond controversy before us that the “Kerala Bank” has no individual members, but only Co-operative Societies who are enrolled as such; while “Urban Banks” have both such as its members. 23. Ineluctably, therefore, going by the plain reading of Section 194A (3)(v) of the “Act”, income credited to or paid by the “Kerala Bank” or by the Urban Banks, to its Co-operative Society members on Time Deposits, would not be exempt from the obligation of having to deduct Tax at Source (“TDS” for ease). But, the afore extracted Clause 42.7 of the Explanatory Note speaks wholly to the contrary; and it is admitted by Sri.Christopher Abraham that the same is binding on the Tax Department - it having been issued by the ‘CBDT’. 24. It consequently would brook no doubt that the obligation or exemption - as the case may be, of and in favour of the Co-operative Banks qua its Cooperative Society members (and not individual members), is underpinned on the statutory prescriptions of the Finance Act, 2015 , read with the Explanatory Note and nothing else. 25. To paraphrase, without the Explanatory Note, no Co-operative Bank may stand entitled to exemption from the requirement to deduct Tax at source from the income on Term Deposits to their membersocieties; and hence the impugned proviso would have no bearing on them. 26. This is apodictic because, the proviso in question is intended solely to attenuate the sweep of the benefit earlier granted, and to confine it to certain categories of Societies alone, to thus remove the earlier blanket exemption. The Co-operative Banks or Urban Banks, never enjoyed such exemption, as per Sections 194A (3)(v) or 194A(3)(viia) of the “Act”; at least qua its member-societies; but obtained it through the Explanatory Note. 27. We will now deal with the further contentions in Batch 1 appeals. 28. The Co-operative Banks or Urban Banks, never enjoyed such exemption, as per Sections 194A (3)(v) or 194A(3)(viia) of the “Act”; at least qua its member-societies; but obtained it through the Explanatory Note. 27. We will now deal with the further contentions in Batch 1 appeals. 28. On the amplitude of the impugned proviso, Sri A.Kumar, learned Senior Counsel instructed by Smt.Mini, Sri.P.C Sasidharan; Sri.M.M.Monaye; Sri. Sudheesh; Sri.C.A.Jojo; O.D.Sivadas – learned counsel for the various appellants, argued that it creates an unreasonable classification among the “Deductor” – Societies, which answers to no intelligible differentia; and without any specific objective being achieved. 29. The learned Senior counsel and counsel for the appellants contended that, until the Finance Act, 2020 , all Co-operative societies which fall within the ambit of Sections 194A (3)(v) and 194A(3) (viia) of the ‘Act’, were fully exempt from having to deduct Tax at source from its member ? societies; but that, through an untenable classification — that too, through a proviso ? substantial numbers among them have now been denied such. They argued that this is discriminatory, without any purpose, intended only to harass and prejudice. 30. Sri.B.G.Harindranath, learned Senior counsel, instructed by Sri.Amit Krishna - appearing for the ‘Kerala Bank’, affirmed that, even if Section 194A (3)(v) of the ‘Act’ may make it appear that his client is liable to deduct ‘TDS’, they are saved from doing so through the ‘Explanatory Note’ to the Finance Act, 2015 , aforementioned. He argued that, therefore, the Writ Petitioners are well justified in having approached this Court against demands made to his client to deduct ‘TDS’ from the amounts due to them. He asserted that, when his client is under no obligation to make any deduction, such demands are untenable, illegal and unlawful; and sought liberty for them to invoke other remedies in future, if it becomes so necessary. 31. The contra - argument of Sri.Christopher Abraham – learned counsel for the Tax Department, is that the prescription to deduct Tax at Source is to primarily augment revenue; and that the original exemption to all “Deductor” co-operative Societies was intended to provide them with enough leverage to compete in the open market, along with the “Kerala Bank”. 31. The contra - argument of Sri.Christopher Abraham – learned counsel for the Tax Department, is that the prescription to deduct Tax at Source is to primarily augment revenue; and that the original exemption to all “Deductor” co-operative Societies was intended to provide them with enough leverage to compete in the open market, along with the “Kerala Bank”. He explained that, however, when it comes to larger Societies, particularly those who have a total turn over of fifty crores during a Financial Year, such an exemption was found not necessary, since they require no protection from competition. He further contended that, providing exemption and revoking such, are exclusively within the domain of the legislature; and that, unless the appellants are to establish that it has been done without competence, or is in a manner perverse to the constitutional scheme, a challenge to it is not possible or permissible. 32. Undoubtedly, the proviso brings in a classification among certain types of societies. When one reads Sections 194A (3)(v) and 194A(3)(viia) of the ‘Act’, it becomes perspicuous that, apart from Co-operative banks and Urban Banks, the other Societies within its sweep would be the Primary Agricultural Credit Societies; Primary Credit Societies and Primary Co-operative Agricultural Rural Development Bank. The “KCS Act”, defines the afore said societies through Sections 2(oaa),2(ob) and 2(oc) respectively. The defining characteristic in all these definitions is that these Societies cannot have Co-operative societies as its members, but only individuals and persons. 33. In contradistinction, going by Section 2(ka) of the “KCS Act”, the State Co-operative Bank (“Kerala Bank”) can enroll only Co-operative banks as their members; while, as per Section 2(ta) thereof, Urban Banks can enroll both Co-operative Societies and individuals as its members. 34. This is the cardinal difference between the two sets of banks and this is what is reflected in the “Act “ also. 35. As seen earlier, viewed litera legis, under Section 194A (3)(v) of the ‘Act’, State Co-operative Banks or Urban Banks, never enjoyed any exemption and are to make the deductions as required under Section 194(A)(1). However, as noticed supra, the “Explanatory Note”, specifically the afore extracted clause 42.7 thereof, seems to create an exemption in their favour – albeit, in the case of Urban Banks, only qua the Societies who are their members and not individuals. However, as noticed supra, the “Explanatory Note”, specifically the afore extracted clause 42.7 thereof, seems to create an exemption in their favour – albeit, in the case of Urban Banks, only qua the Societies who are their members and not individuals. This is what has been noticed by this Court in The Thalapalam Service Co-operative Bank (supra). 36. Merely to reiterate – having been said by us earlier - the impugned proviso is surely not intended for the State Co-operative Bank or the Urban Banks, but only for the other classes of Societies. This is expressly admitted by Sri.Christopher Abraham also. 37. In such perspective, before the proviso was brought in through the Finance Act, 2020 , every Society, other than a Co-operative Bank, was enjoying the exemption. Now, that has been taken away and only those which fall within the stipulated thresholds, as mentioned in the proviso, would continue to obtain it. 38. Interestingly, the “Deductee” - Societies are before us also on the adscititious ground that, since they obtain the benefit of Section 80(P)(1) of the “Act”, deductions at Source become impermissible; and further that their income will be unnecessarily held up through such deductions. 39. Sri.A.Kumar, learned Senior Counsel, expatiated his case, relying upon the judgment of the Hon’ble Supreme Court in Nathpa Jhakri Joint Venture v State of Himachal Pradesh and others [ 2000 (3) SCC 319 ], to argue that the “Deductee” - Societies being statutorily entitled to deduct the interest accrued to them on Term Deposits from their total income, under Section 80(P)(1) read with Section 80P(2)(b) of the ‘Act’, deduction of Tax on it at source is rendered superfluous and inept. He then added that the Co-operative sector in Kerala is a unique one, catering to ordinary citizens and vulnerable sections, which requires support in every manner; and hence that the burden on income, though deductions at source, would cause perilous consequence on the Societies, they being dependent on such sums for their existance. 40. The above submissions were adopted and supported by all other learned counsel for the “Deductee” - Societies; reinforcingly asserting that the impugned proviso takes away benefits reserved to their clients by the afore said two provisions, in an indirect manner. 41. We are afraid that we cannot find favour with the submissions above for more reasons than one, as we will presently enumerate. 42. 41. We are afraid that we cannot find favour with the submissions above for more reasons than one, as we will presently enumerate. 42. As rightly argued by Sri.Christopher Abraham, the grant or withdrawal of exemptions under the Income Tax Act is one which fully falls within the policy realm of the legislature, into which, this Court cannot enter, unless it is found to be perverse and constitutionally impermissible. 43. The stipulations of Section 194A (1) of the ‘Act’ render it mandatory for every person, not being an individual or Hindu undivided family, to deduct Income Tax at the rates in force. It is merely an exemption, which has been carved out for the Cooperative Societies, through Section 194A (3)(v) and 194A(3)(viia). Prior to the Finance Act, 2020 , their exemption was absolute; but it has now been constrained, through certain criteria as mentioned in the impugned proviso. 44. Interestingly, none of the appellants have a case that the Legislature did not obtain the competence to legislate, to bring in the impugned proviso. As noticed above, their sole assertion is that, when they are eligible to reduce the interest earned from their total income, as per Section 80P(1), read with Section 80P(2)(d) of the ‘Act’, a deduction of tax on it at source, is impermissible. 45. But, as correctly noticed by the learned Single Judge, the appellant Societies themselves admit that Section 80(P)(1) of the ‘Act’, read along with Section 80P(2)(d) of it, does not exempt them to pay tax at all; but that the interest income earned from Term Deposits can be deducted from their total income. This is in contra-distinction to the position noticed by the Honourable Supreme Court in Nathpa Jhakri Jont Venture, where, the appellant was found entitled to full exemption from tax. Obviously, the ratio in the said judgment would not apply to the appellants in this case; since they unequivocally concede that, to obtain the benefits under Section 80(P)(1), read with Section 80P(2)(d) of the ‘Act’; they have to file their returns and seek that the component of interest income be deducted from their total income. 46. The adjunct argument of the appellants is that their income is likely to be held up on account of the deduction of tax at source; and they maintain that this will cause prejudice to them. 46. The adjunct argument of the appellants is that their income is likely to be held up on account of the deduction of tax at source; and they maintain that this will cause prejudice to them. Here again, this is not an issue that this Court is competent to deal with on merits because, it falls within the policy realm of the Legislature. However, interestingly, but for the ‘Explanatory Note’ to the Finance Act, 2015 , extracted above, the Co-operative Banks – with which all societies admittedly have large exposure, even to an extent of about 70% of their investments – may have been obligated to deduct tax at source; and, as indited above, the exemption they enjoy from doing so, is not underpinned on the impugned proviso. 47. On the question of constitutionality of the proviso, we find full favour with the views and holdings of the learned Single Judge and find nothing more to be added to it. 48. As regards the contentions of Sri.B.G.Hareendranath, learned Senior Counsel, since we are convinced that the exemption to the ‘Kerala Bank’ and Urban Banks, from deducting ‘TDS’ to their members – societies, do not flow from the impugned proviso, but from the ‘Explanatory Note’ to the Finance Act, 2015 , their remedies and right to legal recourse – as may be available - to any demand contrary to it, are always open to them to pursue. 49. Moving on to the second batch of appeals, they are filed by ‘Deductor’-Societies, who impute that they are being unnecessarily put to prejudice by the alleged unreasonable classification, introduced by the proviso. 50. Dr.K.B.Pradeep – learned counsel for the appellants in these cases, vehemently argued that the classification introduced through the proviso is unreasonable, arbitrary and capricious; further reasserting that it answers to no intelligible differentia. He pointed out that, when the societies in question were earlier given full exemption from having to deduct tax at source, the attenuation of the same – at least with respect to certain among them – is illogical and irrational. He pointed out that, when the societies in question were earlier given full exemption from having to deduct tax at source, the attenuation of the same – at least with respect to certain among them – is illogical and irrational. He contended that this is more so when, by the admitted position afore seen, the ‘Kerala Bank’ – which is the biggest co-operative sector entity, in which all the ‘Deductee’-Societies have substantial exposure – is still exempt from the burden of having to deduct tax at source; and consequently that, such obligation cast upon the ‘Deductor’-Societies that fall into the categories enumerated in the impugned proviso, is unfair, illegal and unconstitutional. 51. In response to this, Sri.Christopher Abraham – learned Standing Counsel for the Income Tax Department, leaned primarily upon his earlier recorded submissions – namely, that the grant or withdrawal of exemptions of the nature involved in this case is the prerogative of the Legislature and that it is guided by certain specified considerations. He conceded that, until Finance Act, 2020 – through which, the impugned proviso was introduced – all the Societies involved, namely the Primary Agricultural Credit Societies, Primary Credit Societies, and the Primary Co-operative Agricultural and Rural Development Banks, were exempt from the requirement to deduct tax at source; but that it has been now imposed on some of them, who fall within the criteria stipulated by the proviso in question. He maintained that this has a valid purpose behind it, namely, that bigger societies need not require the aid of exemption; while, some amount of protection is still granted to the smaller ones, so that they can continue in competition with larger operators, including the ‘Kerala Bank’. 52. When we examine the counter pleadings filed by the Tax Department in these cases, they align with the above recorded submissions of Sri.Christopher Abraham, that exemption from the onus of deduction of Tax at source is retained to smaller societies, to keep them in competition with the ‘Kerala Bank’. However, when we notice that the ‘Kerala Bank’ appears to be even now exempt from the requisite to deduct tax at source, on account of the ‘Explanatory Note’ to the Finance Act, 2015 , this argument perhaps would expose itself to be rather facile. 53. However, when we notice that the ‘Kerala Bank’ appears to be even now exempt from the requisite to deduct tax at source, on account of the ‘Explanatory Note’ to the Finance Act, 2015 , this argument perhaps would expose itself to be rather facile. 53. Nevertheless, when this Court is called upon to evaluate the constitutional validity of the impugned proviso, what is expected to be verified and assessed is not the prejudice that may be caused to individuals or entities, but whether it finds support of the constitutional scheme, and satisfies the test of nomothetic competence under the ‘Pith and Substance’ doctrine. Since none of the parties impel contentions against the Legislature not having the competence to legislate the proviso, that aspect need not engage our attention any further. 54. Reverting to the singular case of the ‘Deductor’-Societies, it is admitted – and which is incontrovertible – that the amounts which they are obligated to deduct at source do not belong to them. It is the payment they are enjoined to make on behalf and to the tax credit of their members. They cannot, hence, allege any prejudice in being asked to deduct tax at source of their members; and, at the best, all that they can possibly say is that, this would put them to some little administrative inconvenience. It does not require us to expatiate that this certainly is not a ground that can be projected by any appellant to challenge the constitutional vires of a provision. As said before, it is within the wisdom of the Legislature to offer exemptions, or to withdraw such; subject only to evaluation of whether it is constitutionally perverse or otherwise. 55. In this context, Sub Rule (b) of the impugned proviso is crucially relevant because, it allays the apprehension of prejudice caused to individuals or member – Societies, ensuring that the threshold income – which becomes amenable to deduction of tax at source - is over a lakh of rupees in the case of a senior citizen and Rs.50,000/- in the case of others; thus rendering only larger payouts of interest and dividend to be subjected to such rigour. 56. 56. In any event, when an individual or entity is subjected to a deduction of tax at source, he/it can claim it back as refund, if he/they are able to establish, through their returns, that he/they are not liable to pay such tax, or any portion of it. 57. We cannot, axiomatically, find any of the contentions of the ‘Deductor’ - Societies against the impugned proviso, to be worthy in law. 58. That brings us to the third batch of Appeals - which are filed by the Revenue, but limited to against a clarification made by the learned Single Judge, subsequent to the judgments. 59. It appears that, after the judgments were delivered, the Writ Petitions were listed immediately, for ‘being spoken to’ by the learned Judge, noticing that interim orders had been earlier issued in each of them, interdicting the ‘Deductor’ – societies from deducting tax at source from their member – societies. 60. The learned Single Judge clarificatorily ordered as under: 2. Immediately upon pronouncement of the judgment, learned counsel for the petitioners brought to the notice of this Court, certain practical difficulties arising from the operation of the interim order. Accordingly, the matter was listed today for addressing those concerns. After hearing the parties, the following clarification is issued: 3. In these cases, though the question of law has been decided in favour of the Revenue, certain practical issues arise concerning the interim orders passed during the pendency of the writ petitions. In all matters, interim orders were in force, staying deduction of amounts towards TDS, and such orders were duly acted upon by all concerned. Reversing the consequences of nondeduction of TDS, which occurred pursuant to the interim orders, would be practically difficult and likely to cause serious legal and procedural complications. Hence, it is only just and proper that the interim orders are made absolute in respect of all transactions up to the date of pronouncement of the judgment., and it is ordered accordingly. This would mean that, in respect of all transactions effected, pursuant to the interim orders passed by this Court in these writ petitions, no adverse consequences shall follow, from the judgment now rendered. This order shall form part of the judgment pronounced by this Court on 25.10.2025. 61. This would mean that, in respect of all transactions effected, pursuant to the interim orders passed by this Court in these writ petitions, no adverse consequences shall follow, from the judgment now rendered. This order shall form part of the judgment pronounced by this Court on 25.10.2025. 61. Sri.Christopher Abraham – learned Standing Counsel for the Revenue, argued that the afore clarification offers an unfair and undeserving advantage to the ‘Deductor’ – Societies from having to face the consequences of violations under the ‘Act’. He contended that, every interim order is only meant to be for the period when the Writ Petition is in force and not beyond it; and hence that the learned Single Judge neither could have confirmed it; nor, protected the ‘Deductors’ from necessary consequences as per the statutory prescriptions. 62. As unreservedly conceded, this Court had issued interim orders interdicting the ‘Deductor’ – Societies from deducting TDS from the interest income of their member – societies, at the time when each of the Writ Petitions were admitted. This was an affirmative injunction ordered by this Court; and obviously, the ‘Deductors’ could not have acted in any manner contrary to it. 63. Pertinently, the Revenue did not attempt to vary or modify these orders; and allowed them to be in force until the Writ Petitions were disposed of. 64. It is uncontestable and beyond pale of argument, that the majesty of the legal system is edificed upon the manner in which orders are implemented and complied with. If it is to be thought otherwise, the integrity of the justice dispensation system would stand compromised. The ‘Deductor’ – Societies, surely had no option, but to obey the orders, which they did; and as said above, the Revenue did not object to such orders until the Writ Petitions were disposed of. 65. It is, therefore, for good cause that the learned Single Judge confirmed the interim orders; because, otherwise, the ‘Deductor’ – Societies would have to face penal and other consequences as per the ‘Act’, solely because they chose to comply with lawfully issued orders. 66. We say so also for another reason, namely, that the Writ Petitions had been pending for a few years; and, by this time, the Assessment Years and Financial Years in question had long passed. 66. We say so also for another reason, namely, that the Writ Petitions had been pending for a few years; and, by this time, the Assessment Years and Financial Years in question had long passed. It would be impossible for any deduction to be made at this time; and this is more so for the reason that each of the assessees would have already filed their returns, to obtain whatever relief that they are entitled to - either under Section 80P(1), read with Section 80P(2)(d) of the ‘Act’ - or otherwise. 67. One cannot hence find the learned Single Judge to have erred in having confirmed the earlier interim orders issued in the Writ Petitions; or in sparing the ‘Deductors’ from adverse consequences for having acted in obedience to such. In the afore circumstances, we dismiss each of these Appeals; but, subject to the afore recorded clarifications and observations.