ARNAV GLOBAL PRODUCTS AND SERVICES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER WARD 12(1)(1), MUMBAI

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ITA 1818/MUM/2026Status: DisposedITAT Mumbai03 August 2026AY 2023-20245 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee had demonstrated its rightful claim to the TDS credit as reflected in Form 26AS, with corresponding income offered to tax. No objections were raised by the revenue. Therefore, the matter was remitted back to the Assessing Officer for verification.

What were the facts?

The assessee claimed TDS credit of Rs. 22,58,122 which was denied by the Assessing Officer and confirmed by the CIT(A) via a rectification order. The assessee argued that the TDS was reflected in Form 26AS and the corresponding income was offered to tax.

What were the issues?

Whether denial of TDS credit is justified when it is reflected in Form 26AS and the corresponding income is offered to tax, and if a technical mismatch can lead to denial of substantive credit.

Which sections of the Income-tax Act were involved?

Section 154,Section 199,Section 205

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCHES, MUMBAI

Before: HON’BLE SHRI PAWAN SINGH & HON’BLE SHRI GIRISH AGRAWAL

For Respondent: Shri Surendra Mohan, Sr. DR
Pronounced: 03.08.2026

INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCHES, MUMBAI BENCH: A BEFORE HON’BLE SHRI PAWAN SINGH, JUDICIAL MEMBER AND HON’BLE SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA 1818/MUM/2026 िनधा�रण वष�/Assmt. Year: 2023-24) ARNAV GLOBAL PRODUCTS INCOME TAX OFFICER AND SERVICES PRIVATE WARD 12(1)(1) LIMITED AAYKAR BHAWAN UNIT NO 1023 IJMIMA TOWER R Vs. MINDSPACE COMPLEX MALAD MUMBAI-400020, MAHARASHTRA WEST, MUMBAI-400064, MAHARASHTRA (��थ� Respondent) (अपीलाथ� Appellant) Permanent Account Number of Assessee: AAUCA6641A िनधा�रती �ारा/Assessee represented by: Shri Sunil Maloo, CA राज� व �ारा/Revenue represented by: Shri Surendra Mohan, Sr. DR

सुनवाई की तारीख / Date of conclusion of hearing: 07.05.2026 घोषणा की तारीख / Date of pronouncement: 03.08.2026 आदेश / ORDER PER GIRISH AGRAWAL, ACCOUNTANT MEMBER: This appeal filed by the assessee is against the order of ADDL/JCIT (A)-2, Hyderabad, vide order no. ITBA/APL/S/250/2025- 26/1084013971(1), dated 25.12.2025, passed against the assessment order by Deputy Commissioner of income tax, CPC, Bengaluru, u/s 154 of the Income-tax Act (hereinafter referred to as the “Act”), dated 12.11.2024, for Assessment Year 2023-24.

2.

Assessee has raised the following grounds of appeal:

ITA No.1818/Mum/2026 Arnav Global Products and Services Pvt. Ltd. Assessment Year 2023-24

1) The order of the Ld. Addl.CIT Appeals is bad in law and on facts, contrary to the evidence on record, and passed in violation of the principles of natural justice. 2) The Ld. Addl.CIT Appeals erred in confirming the rectification order passed under Section 154 by CPC, Bengaluru, whereby TDS credit amounting to Rs. 2258121 out of total TDS of Rs. 2278397 was denied, despite the said TDS being duly reflected in Form 26AS. 3) The Ld. CIT Appeals erred in holding that denial of TDS credit was due to incorrect filing of the return of income and does not constitute a mistake apparent from record, without appreciating that The TDS is duly reflected in Form 26AS The tax has been deducted and deposited with the Central Government The assessee is legally entitled to credit under Sections 199 and 205 of the Income Tax Act, 1961 4) The Ld. Addl.CIT Appeals failed to appreciate that substantive tax credit cannot be denied merely on account of technical mismatch OR clerical error in mentioning TAN in the return of income, particularly when The tax has been duly deducted at source The same stands credited to the Government The credit is verifiable from Form 26AS 5) The denial of TDS credit is contrary to Section 199, which mandates granting credit for TDS to the person from whose income tax has been deducted and Section 205, which prohibits direct demand of tax from the assessee WHARE tax has already been deducted at source. 6) The action of the Department in denying TDS credit results in unjust enrichment of the Revenue and leads to double taxation of the same income, which is contrary to the scheme, intent, and equity principles underlying the Income Tax Act, 1961. 7) The Appellant craves leave to add, amend, alter, modify, OR withdraw any ground at the time of hearing.

3.

The issue raised by the assessee in the present appeal relates to denial of TDS credit by the ld. Assessing Officer as claimed by the assessee in its return of income for which the corresponding income has been offered to tax. In this respect, assessee has furnished a

ITA No.1818/Mum/2026 Arnav Global Products and Services Pvt. Ltd. Assessment Year 2023-24

written submission explaining its case, corroborating and reconciling it with relevant documentary evidence on record which includes, its audited profit and loss statement wherein Revenue from operations is reported, entries in Form-26AS as reflected to match it with the income reported in the return form and the profit and loss statement.

3.1. Contents of the submission made by the assessee in this regard are extracted below for ready reference. 1. Issue before the Hon'ble ITAT - Denial of TDS Credit: The Assessee claimed total TDS credit of Rs. 22,78,397/-, whereas credit granted is only Rs. 20,275/-, resulting in denial of TDS credit of Rs. 22,58,122/-.

2.

Amount of TDS amounting to Rs 22,78,397/- as reflecting in Form 26AS relevant Screenshot at Pg 8 of CIT(A) Order.

Sr.No. Name of Deductor TAN of Total Amount Paid/ Total tax deducted Total TDS Deposited Deductor Credited AARAV GLOBAL PRODUCTS AND SERVICES PRIVATE L1MITHD 359452250.00 2258122.00 2258122.00 1 MumA47296E Sr.No. Section Transaction Date Status of Date of Booking Remarks Amount Tax Deducted TDS Deposited Booking Paid/Credited 1 I94C 31-Mar-2023 F 05 Oct 2023 -- 99930000.00 1998600.00 1998600.00 2 194Q 31-Mar-2023 F 05-Oct-2023 -- 259522250.00 259522.00 259522.00

Sr.No. Name of Deductor TAN of Total Amount Paid/ Total tax deducted Total TDS Deposited Deductor Credited

2 Jautri Infra Pvt. Ltd. MUMJI9530A 1013750.00 20275.00 20275.00

Remarks Sr.No. Section Transaction Date Status of Date of Booking Amount Tax Deducted TDS Deposited Booking Paid/Credited

I94C 31-Mar-2023 F 20-Aug-2023 1 -- 84503.00 1690.00 1690.00

I94C 31-Mar-2023 F 20-Aug-2023 2 -- 120858.00 2417.00 2417.00

I94C 31-Mar-2023 F 20-Aug-2023 3 -- 68358.00 1367.50 1367.50

I94C 31-Mar-2023 F 20-Aug-2023 4 -- 258798.00 5176.00 5176.00

I94C 31-Mar-2023 F 20-Aug-2023 5 -- 98467.00 1969.00 1969.00

I94C 31-Mar-2023 F 20-Aug-2023 6 -- 267047.00 5341.00 5341.00

ITA No.1818/Mum/2026 Arnav Global Products and Services Pvt. Ltd. Assessment Year 2023-24 I94C 31-Mar-2023 F 20-Aug-2023 7 -- 115719.00 2314.50 2314.50

3.

Income duly offered in ITR - The corresponding income has been duly offered in the ITR working at Pg 5 of CIT(A) Order. Particulars of Income Amount IDS Claimed in ITR Turnover from Rs.9,99,30,000/- Rs.19,98,600/- Aarav Global Products And Services Private Limited U/S194C, on services Rs.25,95,22,250/- Rs.2,59,522/- Aarav Global Products And Services Private Limited U/S194Q on Goods Jautri-Infra-Private Limited U/SI94- Rs. 10,13,750/- Rs.20.275/- R and N Croup Rs.1,99,11,112/- Rs..Nil Total Turnover as per profit and loss account Rs.38,03,77,112/- Rs.22,78,397/-

4.

Thus, all conditions of Section 199 are duly fulfilled. The turnover is also matched with the turnover reported in the audit report, and the relevant annexure to the Statement of Profit and Loss Account reflecting the Assessee's revenue is attached as Annexure-1. Extracts as follows: ARNAV GLOBAL PRODUCTS AND SERVICES PRIVATE LIMITED CIN: U72900MH2021PTC353732 Statement of Profit and Loss For the Year Ended March 31, 2023 (Amount in Hundreds, except otherwise stated) Particulars Note No. As at March 31, 2023 As at March 31, 2022 IINR) —— — (INR) 3(1) 3(2) 38,03,771.12 60,322.53 1. Revenue from operations II. Other Income III. Total Income (1 + II) 38,03,771.12 60,322.53

4.

Before us, ld. Counsel for the assessee has evidently demonstrated the rightful claim toward TDS credit as reflected in Form 26AS for which corresponding income has been duly offered to tax in the return form. On confrontation of these submissions, there is nothing objectionable placed on record by the other side.

ITA No.1818/Mum/2026 Arnav Global Products and Services Pvt. Ltd. Assessment Year 2023-24 4.1. In the given set of facts and the submissions so made, we find it appropriate to remit this matter back to the file of ld. Jurisdictional Assessing Officer (JAO) for the very limited purpose of verification of the factual date as extracted above and allow the TDS credit as claimed by the assessee. Accordingly, grounds raised by the assessee in this regard are allowed for statistical purposes.

5.

In the result, appeal of the assessee is allowed for statistical purposes. Order is pronounced in the open court on 03 August, 2026

Sd/- Sd/- (Pawan Singh) (Girish Agrawal) Judicial Member Accountant Member Dated: 03.08.2026 MP, Sr.P.S. Copy to: 1 The Appellant 2 The Respondent 3 DR, ITAT, Mumbai 4 Guard File 5 CIT BY ORDER,

(Dy./Asstt.Registrar) ITAT, Mumbai

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