Applicability of sec 269st to business correspondents (bc) of banks

Being AGENT TO PRINCIPAL, the same principle should apply; at least for any transaction carried on its behalf.

Accodring to the Finance Bill 2017, the term banking company as mentioned in Section 269ST will have the same meaning as per explanation to Section 269SS, which does not include a Business Correspondent of a Bank as Banking Company.

So what should be done in this case?

The characteristics of transactions differ, so the same defination cannot be adopted in each case. 

All in all, there are many such grey areas for the final implementation of the new section 269ST, like agriculturalists, marriage function receipts, bank withdrawals etc. etc. which are much different then the intention for which the section is applied for; and hence clarification from CBDT is much eagerly awaited.