BRIG RESOLUTION SERVICES PRIVATE LIMITED,MUMBAI vs. CIRCLE 14(1)(2), MUMBAI

ITA 6361/MUM/2025Status: DisposedITAT Mumbai22 December 2025AY 2020-21Bench: SHRI OM PRAKASH KANT (Accountant Member), SHRI RAHUL CHAUDHARY ( (Judicial Member)6 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee should be allowed credit for TDS deducted and deposited, even if in a subsequent year, provided the corresponding income was offered to tax in the relevant year. The Assessing Officer was directed to verify the TDS credit.

What were the facts?

The assessee claimed TDS credit for ₹13,06,152, but the CPC granted only ₹10,84,152, citing a mismatch with Form 26AS. The assessee explained that the deductor deposited the TDS in a subsequent financial year due to a reduction in TDS rates.

What were the issues?

Whether TDS credit can be allowed when it does not reflect in Form 26AS for the relevant assessment year due to the deductor's actions. The issue of manual intervention versus system-driven processing of TDS credits.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 154

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “B” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI RAHUL CHAUDHARY

For Appellant: Mr. Sunil Hirawat, Mr. Leyaqat Ali Aafaqui, Sr. DR
Hearing: 22/12/2025

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against order dated 20.08.2025 passed by the Ld. Additional/Joint Commissioner of Income-tax (Appeals) – 3 Bengaluru [in short ‘the Ld. CIT(A)’] for assessment year 2020-21. 2. Briefly stated, the assessee filed the return of income on 22.01.2021 declaring total income of ₹76,90,890/-. The return was Brig Resolution Services Pvt. Ltd. Brig Resolution Services Pvt. Ltd. processed by the Central Processing Centre (CPC) and an intimation processed by the Central Processing Centre (CPC) and an intimation processed by the Central Processing Centre (CPC) an

The order continues below.

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