ESTATE OF RANJANA PRANLAL DOSHI THROUGH L/H CHANDRAVADAN PRANLAL DOSHI,PUNE vs. DCIT CIRCLE - 5, PUNE

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA Nos.1979 & 1980/PUN/2025 िनधा�रण वष� / Assessment Years : 2021-22 & 2020-21 Estate of Ranjana Pranlal Vs. DCIT, Circle-5, Pune. Doshi, Through L/H Chandravadan Pranlal Doshi, A-11, Kent Exclusive Co-op. Housing Society, Shivarkar Road, Wanowarie, Pune- 411040. PAN : CFIPD0184D Appellant Respondent Assessee by : Mrs. M. N. Kulkarni Revenue by : Shri Basavaraj Hiremath Date of hearing : 23.02.2026 Date of pronouncement : 28.04.2026 आदेश / ORDER PER VINAY BHAMORE, JM: Both the above captioned appeals filed by the assessee are directed against the separate orders dated 26.06.2025 passed by Ld. Addl./JCIT(A)-3, Chennai [‘Ld. CIT(A)’] for the assessment year 2020-21 and 2021-22 respectively.

2 ITA Nos.1979 & 1980/PUN/2025 2. Since identical facts and common issues are involved in both the above captioned appeals of the assessee, therefore, we proceed to dispose of the same by this common order. 3. First, we shall take up the appeal of the assessee in ITA No.1980/PUN/2025 for A.Y. 2020-21 for adjudication as the lead case. ITA No.1980/PUN/2025, A.Y. 2020-21 : 4. The appellant has raised the following grounds of appeal :- “1. Honourable Addl/JCIT(A)-3 Chennai has erred in Not granting credit for TDS deducted Rs.4,73,668/- though relevant Income is offered and taxed as Income of Estate of Late Ranjana Pranlal Doshi in Intimation u/s 143(1) so also in Order u/s 154. Appellant prays for grant of the said credit of TDS. 2. Without Prejudice, to ground No. 1, Appellate Authority has erred in not deleting the Income related to TDS Credit not given. 3. Lower Authorities have erred in levying interest u/s 234A without giving credit for TDS. Appellant denies Liability to interest and prays for reduction. 4. Appellant prays for just and equitable relief. 5. Appellant prays to add, alter amend, clarify, explain and/or withdraw the ground/s as occasion may demand.” 5. Facts of the case, in brief, are that on 04-05-2014 the assessee Ranjana Pranlal Doshi expired intestate and her brother with the consent of other legal heirs became legal heir on the income tax

3 ITA Nos.1979 & 1980/PUN/2025 portal and furnished the return of income for assessment year 2015-16 and 2016-17. For subsequent years the return could not be furnished since portal not allowed the filing. Thereafter, some parties other than legal heirs claimed her last will in the court of law and the matter is still subjudice in the higher court. The legal heirs approached Pr.CCIT & were suggested to obtain PAN in the name of Estate of Ranjana Pranlal Doshi which was issued and thereafter the returns were continuously filed on the PAN CFIPD0184D of Estate of Ranjana Pranlal Doshi. The return of income for assessment year 2020-21 was furnished on 31.12.2020 declaring total income of Rs.71,20,919/- and claiming credit for TDS of Rs.4,73,668/-. Vide intimation order dated 05.02.2021 passed u/s 143(1) of the IT Act the CPC processed the income tax return and accepted the returned income, however credit of TDS of Rs.4,73,668/- was denied instead interest u/s 234A was charged. The assessee filed rectification application u/s 154 of the IT Act and tried to explain that the TDS was deducted on the erstwhile PAN AARPD8092J of Late Ranjana Pranlal Doshi, however the income was disclosed on new PAN CFIPD0184D obtained in the name of

4 ITA Nos.1979 & 1980/PUN/2025 Estate of Ranjana Pranlal Doshi. Application u/s 154 was not allowed and the credit of TDS was not given by CPC. 6. Being aggrieved with the above rectified intimation order wherein credit of TDS was not allowed, the assessee preferred an appeal before Ld. CIT(A). After considering the reply and submissions of the assessee, Ld. CIT(A) dismissed the appeal filed by the assessee. 7. It is the above order against which the assessee is in appeal before this Tribunal. 8. We have heard Ld. counsels from both the sides and perused the material available on record including the paper book furnished by the assessee wherein copy of orders of first appeal passed by Ld. CIT(A) for assessment years 2022-23 and 2023-24 are also enclosed. 9. In this regard, we find that it is the sole contention of the Counsel of the assessee that Ld. CIT(A) has already allowed the appeal of the assessee wherein identical grounds were raised for Asstt Year 2022-23 and for Asstt Year 2023-24. In this regard, Ld. counsel relied on separate order dated 04.01.2024 and 02.03.2024

5 ITA Nos.1979 & 1980/PUN/2025 passed by Ld. CIT(A) wherein the credit of TDS was directed to be allowed to Estate of Ranjan Pranlal Doshi by observing as under :- “4.3 It is pertinent to point out here that once the income has been offered for taxation in a particular year, the corresponding TDS credit is also to be allowed to the tax payer in terms of provisions Rule 37BA read with section 199 of the IT Act. In the appellant's case, the issue is that the TDS of Rs.5,36,246/- is still appearing in Old PAN which can be corrected by the Jurisdictional Assessing Officer (JAO) after following the necessary procedure in ITBA. Therefore, the JAO is directed to make necessary correction and allow the relief to the appellant after obtaining the legal heir certificate.” 10. From a perusal of above appellate order passed in the case of the assessee for asstt year 2022-23 & 2023-24 wherein identical issue was decided in favour of the assessee it becomes crystal clear that Ld. CIT(A) has directed the Jurisdictional Assessing Officer i.e. JAO to allow the relief to the appellant after obtaining legal heir certificate. Under these circumstances, we are of the considered opinion that Ld. CIT(A) cannot take a different view than that which has already been taken by him in the case of the same assessee, since there are no change in the facts and circumstances of the case. 11. Accordingly, in view of above discussion and with the consent of Ld. DR, & also in the light of decisions already passed by Ld.

6 ITA Nos.1979 & 1980/PUN/2025 CIT(A) in the case of assessee itself, we deem it appropriate to set-aside the impugned order dated 26.06.2025 passed by Ld. CIT(A) for Asstt Year 2020-21 and restore the matter back to the file of the Jurisdictional Assessing Officer to follow the directions already given by Ld. CIT(A) in its orders dated 04.01.2024 & order dated 02.03.2024 passed for assessment years 2022-23 & 2023-24 respectively in the case of assessee itself. Accordingly, the grounds of appeal raised by the assessee are allowed for statistical purposes. 12. In the result, the appeal filed by the assessee in ITA No.1980/PUN/2025 for A.Y. 2020-21 is allowed for statistical purposes. ITA No.1979/PUN/2025, A.Y. 2021-22 : 13. Since identical facts and issues are involved in the appeal of the assessee in ITA No.1979/PUN/2025 for A.Y. 2021-22 with the appeal of the assessee in ITA No.1980/PUN/2025 for A.Y. 2020-21 therefore, our decision in ITA No.1980/PUN/2025 for A.Y. 2020-21 shall apply mutatis mutandis to the appeal of the assessee in ITA No.1979/PUN/2025 for A.Y. 2021-22. Accordingly, the appeal of

7 ITA Nos.1979 & 1980/PUN/2025 the assessee in ITA No.1979/PUN/2025 for A.Y. 2021-22 is also allowed for statistical purposes. 14. In the result, the appeal filed by the assessee in ITA No.1979/PUN/2025 for A.Y. 2021-22 is allowed for statistical purposes. 15. To sum up, both the above captioned appeals filed by the assessee are allowed for statistical purposes. Order pronounced on this 28th day of April, 2026. Sd/- Sd/- (MANISH BORAD) (VINAY BHAMORE) ACCOUNTANT MEMBER JUDICIAL MEMBER पुणे / Pune; �दनांक / Dated : 28th April, 2026. Sujeet/DOC Sujeet Kumar Digitally signed by Sujeet Kumar Sharma Sharma Date: 2026.04.30 12:11:12 आदेश क� �ितिलिप अ�ेिषत / Copy of the Order forwarded to : +05'30' अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Addl./JCIT(A)-3, Chennai. 4. The Pr.CIT/CIT concerned. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, “A” ब�च, 5. पुणे / DR, ITAT, “A” Bench, Pune. गाड� फ़ाइल / Guard File. 6. आदेशानुसार / BY ORDER, // True Copy // Assistant Registrar आयकर अपीलीय अिधकरण, पुणे / ITAT, Pune.