What did the Tribunal hold?

The Tribunal held that the issue of TDS credit requires further examination. It directed the Assessing Officer to grant credit for the TDS amount as reflected in Form 26AS after providing the assessee an opportunity to be heard.

The assessee company filed its return of income, which was processed under section 143(1). The CPC gave short credit for TDS, citing a discrepancy that included GST in Form 26AS while the assessee's books excluded it. The CIT(A) confirmed the AO's action.

What were the issues?

Whether the assessee is entitled to full TDS credit as per Form 26AS, and whether the processing under section 143(1) is appropriate for debatable issues.

Inzi Controls India Ltd. vs DCIT | ITAT Chennai 2026

Income Tax Appellate Tribunal, CHENNAI BENCHES, CHENNAI

Before: HON’BLE INTURI RAMA RAO & HON’BLE MANU KUMAR GIRI

आदेश / ORDER

PER INTURI RAMA RAO, ACCOUNTANT MEMBER: This appeal filed by the Assessee directed against the order of ld.Commissioner of Income Tax(Appeal)[NFAC], dated 29.07.2025 passed under section 250 of the Income Tax Act, 1961 for the 2023-24.

The Assessee raised the following grounds of appeal : “(1) The order of the Assessing Officer is erroneous and is contrary to the principles of natural justice, fair-play and equity and the facts and circumstances of the case.

143(1) is an intimation not Assessment Order

(ii) The Learned AO/CIT(A) ought to have realized an order u/s 143(1) is merely an intimation and debatable issues cannot be passed vide the same. It has to go through the process of Assessment.

(iii) The Learned AO/CIT(A) has also failed to provide reasons for making an addition.

TDS Credit Not Given as per Form 26AS:

(iv) The Learned AO/CIT(A) has failed to give the eligible credit as per Form 26AS.

(v) The Learned AO/CIT(A) failed to note that the turnover shown is excluding GST, as per requirements as per ICDS.

(vi) The Learned AO/CIT(A) stating that only a portion of the TDS should be allowed is totally wrong and is without regard to the manner of accounting followed.

(vii) The Learned AO/CIT(A) failed to note that the turnover shown and the TDS claimed perfectly match and there is no reason for any kind of disallowance.

(viii) Any other ground that may be raised at the time of personal hearing.”

Briefly the facts of the case are that the appellant company is duly incorporated under the provisions of Companies Act. It is engaged in the business of oil filter, fuel filter and plastic engineering parts of automobile industry. The Return of Income for the Assessment Year 2023-24 filed on 16.11.2023 disclosing income of Rs.29,53,69,171/-. The said Return of Income was processed by CPC u/s.143(1) of the Act vide intimation dated 07.11.2024. While doing so, the CPC had given short credit for TDS by giving credit of Rs.5,79,32,645/- as against the claim of Rs.5,86,00,724/-. It is submitted that the discrepancy in the income show in Form-26AS includes GST on which TDS has been deducted by the customers whereas, in the books of account, the income is recognized excluding with the GST as per the recognized accounting standards.

Being aggrieved by the above intimation, the appellant preferred an appeal before ld.CIT(A) who vide impugned order confirmed the action of the Assessing Officer.

Being aggrieved by the order of ld.CIT(A), the appellant is in appeal before us in the present appeal. It is submitted that CPC given short credit of TDS Rs.6,68,078/- despite the fact that the TDS is reflected in Form-26AS.

On the other hand, Learned Sr.DR opposed the above submissions.

We heard rival submissions and perused the material available on record. The issue that arises for our consideration credit to be TDS amount as reflected in Form-26AS. On careful perusal of the submissions made by both the sides, we are of the considered opinion that the matter requires remand to the file of Assessing Officer with a direction to give credit for TDS amount as reflected in Form-26AS for the relevant assessment year after affording opportunity of being heard to the appellant.

In the result, appeal of the assessee is partly allowed for statistical purpose. Order pronounced in the open Court on 25th May, 2026.

Sd/- Sd/- (INTURI RAMA RAO) (MANU KUMAR GIRI) JUDICIAL MEMBER ACCOUNTANT MEMBER Chennai; िदनांक / Dated : 25th May, 2026 SGR, Sr.PS

आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The CIT Chennai/Madurai/Coimbatore/Salem. 4. �वभागीय ��त�न�ध,आयकर अपील�य अ�धकरण, “ए” ब�च, चे�नई/ DR, ITAT Chennai. गाड� फ़ाइल / Guard File. 5. GANGADHAR Digitally signed by GANGADHARA RAO A RAO SALEELA Date: 2026.06.03 SALEELA 15:47:17 +05'30'

INZI CONTROLS INDIA LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

Recent GST High Court judgments