APARAJITHA SOFTWARE SERVICES PRIVATE LIMITED,MADURAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE, MADURAI, MADURAI

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ITA 1859/CHNY/2026Status: DisposedITAT Chennai27 October 2026AY 2022-2311 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the matter required fresh examination at the level of the Assessing Officer (AO). The Tribunal admitted the MOU dated 01.01.2022 as additional evidence. It observed that the AO and CIT(A) had not independently examined the nature of the transaction and had restricted TDS credit solely based on income offered in the return. The Tribunal clarified that if the assessee's plea under Section 47(v) is accepted, the tax deducted would be excess tax, entitling the assessee to a refund under Section 237. Conversely, if any part of the receipt is found to be chargeable to tax, credit for the corresponding TDS would be given. The Tribunal set aside the order of the CIT(A) and restored the issue to the file of the AO with directions to examine the applicability of Section 47(v), verify the TDS deduction and deposit, reconcile the shortfall in credit, and allow TDS credit in accordance with law. The AO was also directed to recompute consequential interest and pass a speaking order. The Tribunal expressed no opinion on the merits of the applicability of Section 47(v) or the taxability of the receipt.

What were the facts?

The assessee, Aparajitha Software Services Private Limited, filed its return for AY 2022-23 declaring income under Section 115BAA. The CPC processed the return under Section 143(1) and raised a demand of Rs. 22,90,430 due to a mismatch in TDS credit. The assessee claimed TDS credit of Rs. 1,56,75,393, while the CPC allowed Rs. 1,36,04,338, resulting in a difference of Rs. 20,71,055. This difference arose from the transfer of intangible assets and intangible assets under development to its wholly-owned holding company, Aparajitha Corporate Services Private Limited (ACSL), for Rs. 2,84,69,340. ACSL had deducted TDS of Rs. 28,46,934 under Section 194J(b) on this amount and deposited it under the assessee's PAN. The assessee contended that this transfer was not a taxable transfer under Section 47(v) of the Act. Rectification requests to the CPC and the AO were unsuccessful. The CIT(A) upheld the AO's action of restricting TDS credit to the income offered.

What were the issues?

1. Whether the Learned Commissioner of Income Tax (Appeals) erred in confirming the Assessing Officer's action of restricting the credit of tax deducted at source (TDS) and not allowing the entire TDS credit of Rs. 1,56,75,393/- as claimed by the Appellant, which is duly reflected in Form 26AS, AIS and TIS for the relevant assessment year, turning on Section 199 and Rule 37BA of the Income-tax Rules, 1962. 2. Whether the Learned Commissioner of Income Tax (Appeals) erred in affirming the order of the Learned Assessing Officer, who, without independent verification, confirmed the denial of TDS credit by mechanically invoking Rule 37BA and relying solely on a comparison between receipts in Form 26AS and those offered in the return, without examining the nature and taxability of the underlying transactions, turning on Section 143(1) and Rule 37BA. 3. Whether the Learned Commissioner of Income Tax (Appeals) failed to appreciate that the difference between receipts in Form 26AS and those offered in the return arose on account of the transfer of intangible assets covered by Section 47(v) of the Act. Assessee's Contentions: The assessee argued that the transfer of intangible assets to its wholly-owned holding company was not a taxable transfer under Section 47(v) of the Act, as the conditions were fulfilled. Therefore, no taxable income arose from this transaction, and the full TDS credit should be allowed. The assessee also sought admission of the MOU dated 01.01.2022 as additional evidence. The assessee relied on Section 47(v) of the Act. Revenue's Contentions: The revenue, through the AO and CIT(A), contended that TDS credit should be restricted to the income offered by the assessee in its return of income. The authorities relied on a comparison between receipts in Form 26AS and income offered in the return, invoking Rule 37BA.

Which sections of the Income-tax Act were involved?

Section 115BAA,Section 143(1),Section 154,Section 194J,Section 199,Section 205,Section 234A,Section 234B,Section 234C,Section 237,Section 47(v),Section 45,Section 37BA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S. R. RAGHUNATHA

Hearing: 13.08.2026Pronounced: 27.10.2026

आयकरअपीलीयअधिकरण,‘बी ’न्यायपीठ,चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI श्रीमनुकुमारगिरर, न्याययकसदस्यएवंश्रीएस.आर.रघुनाथा, लेखासदस्यकेसमक्ष BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.1859/Chny/2026 ननिाारणवर्ा / Assessment Year: 2022-23 Aparajitha Software Services Private The Deputy Commissioner of Limited vs. Income-tax 5A, Rathinasamy Nadara Road Corporate Circle Bibikulam Madurai. Madurai – 625 002. [PAN:AAOCA0333P] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) अपीलाथीकीओरसे/Appellant by : Ms. Sandhyaarthi T, CA प्रत्यथीकीओरसे/Respondent by : Shri E.Elango, JCIT सुनवाईकीतारीख/Date of Hearing : 13.08.2026 घोर्णाकीतारीख/Date of Pronouncement : 27.10.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM : This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals)-1, Visakhapatnam [hereinafter “the Ld. CIT(A)”] dated 21.01.2026, arising out of the rectification order dated 10.12.2024 passed u/s.154 of the Income-tax Act, 1961 (“the Act” hereinafter) by the Deputy Commissioner of Income-tax, Corporate Circle, Madurai (hereinafter referred to as “the AO”), for the assessment year 2022-23.

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2.

The brief facts of the case are that the assessee is a private limited company engaged, inter alia, in computer software development, web-content management solutions, development and implementation of web-based application software and allied services. For the assessment year 2022-23, the assessee filed its return of income on 27.10.2022 declaring total income of Rs.8,44,74,540/- under the regime contained in section 115BAA of the Act and claiming a refund of Rs.1,84,990/-. 3. The Central Processing Centre (CPC), Income-tax Department, processed the return and issued an intimation u/s.143(1) of the Act on 13.05.2023, accepting the returned income. However, a demand of Rs.22,90,430/-, including interest u/s.234B and 234C of the Act, was raised as a consequence of a mismatch between the credit for tax deducted at source (TDS) claimed by the assessee in the return and the credit allowed by the CPC. The details of the TDS credit claimed and allowed are as under:- Particulars Amount (in Rs.) TDS credit claimed in ITR 1,56,75,393 TDS credit allowed by CPC 1,36,04,338 Difference 20,71,055

4.

According to the assessee, the difference primarily relates to the transfer of intangible assets under development and intangible assets by it to its wholly owned holding company, M/s.Aparajitha Corporate Services Private Limited (ACSL), for a total consideration of Rs.2,84,69,340/-. ACSL deducted tax of Rs.28,46,934/- u/s.194J(b) of the Act on this amount and deposited the same under the PAN of the assessee. The break-up of the amount so transferred is as under:- Particulars Amount (in Rs.) Transfer of intangible asset under 2,19,70,989 development

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Particulars Amount (in Rs.) Transfer of intangible asset under 10,50,000 development Transfer of intangible asset 54,48,351 Total 2,84,69,340

5.

The assessee submitted that the transferred assets were recorded in its audited books as ‘intangible assets’ and ‘intangible assets under development’, as evidenced by Note 5(d) to its financial statements. The transfer was effected through a Memorandum of Understanding dated 01.01.2022 (“the MOU”) between the assessee (ASSL) and ACSL. Under the MOU, the developed existing Compfie and allied products (‘intangible assets’) were agreed to be transferred to ACSL “with all rights” as per Schedule III; Compfie 2 and Compfie Law (‘intangible assets under development’) were separately transferred as per Schedule IV; and the external-vendor contract relating to Compfie Law was assigned to ACSL for completion of the product and payment of the remaining vendor consideration. The MOU further provided that post-transfer employee costs, completion work, client support and monthly consultancy services would be separately charged by the assessee. 6. It was the case of the assessee that throughout the relevant previous year the whole of its share capital was held by ACSL, an Indian company, and that the transfer of the intangible assets and intangible assets under development to its holding company is therefore a transaction falling within section 47(v) of the Act, which is not a “transfer” for the purposes of section 45 of the Act, subject to fulfilment of the prescribed conditions. Hence, no taxable income arose in the hands of the assessee on this transaction, though tax had been deducted and deposited in its name. 7. The assessee filed a rectification request with the CPC on 07.06.2023, seeking reprocessing of the return. The CPC passed an order u/s.154 of the Act on the same day without making any rectification. On 16.08.2023, the

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assessee filed a rectification petition before the jurisdictional AO, seeking correction of the demand. The assessee also filed further rectification requests through the e-filing portal on various dates; the CPC passed an order u/s.154 on 23.08.2024 without any modification in the demand, and a further request dated 28.11.2024 was rejected on 08.01.2025. 8. The jurisdictional AO, vide order u/s.154 of the Act dated 10.12.2024, also declined to modify the demand raised in the intimation u/s.143(1) dated 13.05.2023. The AO observed that the total receipts disclosed by the assessee in the return of income for the year amounted to Rs.12,76,06,091/- and that the TDS credit corresponding to the receipts so offered to tax had already been granted in the intimation; accordingly, no further TDS credit was considered allowable. 9. The assessee carried the matter in appeal before the Ld.CIT(A) on 09.05.2025, filing detailed submissions and documentary evidence explaining the asset transfer, section 47(v) of the Act, the TDS entries and the absence of taxable income from the transaction. The Ld.CIT(A), vide order dated 21.01.2026, upheld the action of the AO in restricting the TDS credit to the extent corresponding to the income offered by the assessee in the return of income. It is the grievance of the assessee that the Ld.CIT(A) merely accepted the findings of the AO without independently examining the nature of the transaction, and without appreciating that the difference between the receipts reflected in Form 26AS and the income offered in the return arose on account of the transfer of intangible assets covered by section 47(v) of the Act. 10. Aggrieved, the assessee is in appeal before us. Along with the appeal, the assessee has filed a paper book and has sought admission of the MOU dated 01.01.2022 as additional evidence. It is submitted that the MOU, entered into between ACSL (the holding company) and the assessee (its wholly owned subsidiary) for the transfer of intangible assets, intangible assets under development and IT infrastructure support functions along with related IT

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assets, functions and personnel, was not furnished before the Ld.CIT(A), as the assessee, which handled the first appeal itself, was under the impression that the details furnished were sufficient for adjudication. On taking over the matter, the present counsel identified the MOU as a document having a direct bearing on the issue. The assessee submits that the omission was neither deliberate nor intended to withhold material evidence, and prays that the MOU be admitted in the interest of justice. 11. The assessee has raised the following grounds of appeal:- 1. The order passed by the Learned Commissioner of Income Tax (Appeals) [“Ld. CIT(A)”] is contrary to the facts and circumstances of the case and the provisions of law and is therefore unsustainable. 2. The Ld. CIT(A) erred in confirming the action of the Assessing Officer in restricting the credit of tax deducted at source (TDS) and not allowing the entire TDS credit of Rs.1,56,75,393/- as claimed by the Appellant, which is duly reflected in Form 26AS, AIS and TIS for the relevant assessment year. 3. The Learned Commissioner of Income Tax (Appeals) [“Ld. CIT(A)”] erred in affirming the order of the Learned Assessing Officer [“Ld. AO”], who, without any independent verification or application of mind, merely confirmed the denial of TDS credit originally made in the Intimation Order under section 143(1) dated 13.05.2023 passed by the Central Processing Centre (CPC), by mechanically invoking Rule 37BA of the Income-tax Rules, 1962 and relying solely on a comparison between receipts appearing in Form 26AS and those offered in the return of income, without examining the nature and taxability of the underlying transactions. 4. The Ld. CIT(A) failed to appreciate that the difference between the receipts appearing in Form 26AS and the receipts offered in the return of income arose on account of the transfer of intangible assets amounting to Rs.2,84,69,340/-, by the Appellant, a wholly owned subsidiary, to its holding company, which transaction is specifically covered under Section 47(v) of the Income-tax Act, 1961 and therefore does not give rise to income chargeable to tax. 5. The Ld. CIT(A) erred in not appreciating that the aforesaid transaction represents transfer of a capital asset at book value, duly reflected in the books of account of the Appellant, and therefore cannot be treated as income chargeable under the head “Profits and Gains of Business or Profession.” 6. The Ld. CIT(A) failed to appreciate that tax was deducted at source by the holding company on the said transaction and duly deposited with the Government and therefore the Appellant is entitled to credit of such tax in accordance with the provisions of Sections 199 and 205 of the Income-tax Act, 1961.

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7.

The Ld. CIT(A) failed to appreciate that the Appellant had filed a rectification petition before the jurisdictional Assessing Officer under Section 154 of the Act seeking grant of full TDS credit, which was rejected on the ground that the issue does not constitute a mistake apparent from record and that the Appellant may pursue alternate remedies under the Act. The Ld. CIT(A), instead of examining the issue on merits, has merely affirmed the reasoning of the Assessing Officer. 8. The Ld. CIT(A) erred in passing a non-speaking order by merely relying upon the findings of the Assessing Officer without independently examining the facts, documentary evidence, legal submissions and judicial precedents placed on record by the Appellant. 9. The Ld. CIT(A) failed to appreciate that denial of credit of tax already deducted and deposited results in retention of tax without corresponding tax liability, which is contrary to the scheme of the Act and violative of Article 265 of the Constitution of India, which mandates that no tax shall be levied or collected except by authority of law. 10. The Ld. CIT(A) erred in confirming the consequential levy of interest under Sections 234A and 234B, which arises solely on account of the wrongful denial of tax credit. 11. The Appellant craves leave to add, alter, amend or withdraw any or all of the above grounds at the time of hearing.

12.

The Ld.DR, Shri E. Elango, JCIT, relied on the orders of the authorities below. He submitted that the CPC and the AO had granted TDS credit corresponding to the receipts of Rs.12,76,06,091/- disclosed and offered to tax in the return of income, and that credit for the balance TDS could not be allowed since the corresponding receipt had not been offered to tax by the assessee. He further submitted that the scope of section 154 of the Act is confined to a mistake apparent from the record, and that the claim now put forward on the basis of section 47(v) of the Act involves a debatable question which cannot be examined in rectification proceedings. As regards the MOU, he submitted that it was not produced before the authorities below and the prayer for its admission as additional evidence may not be entertained. 13. Per contra, the Ld.AR, Ms.Sandhyaarthi T, CA, reiterated the facts narrated above and relied on the paper book filed, including the MOU. She submitted that the entire amount of Rs.2,84,69,340/- represents consideration for the transfer of intangible assets and intangible assets under development, recorded as such in the audited books, by a wholly owned subsidiary to its Indian holding company, which is squarely covered by section 47(v) of the Act and therefore gives rise to no income chargeable to tax, whether under the head ‘Capital gains’ or ‘Profits and gains of

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business or profession’. She submitted that tax deducted by ACSL on the said amount had been deposited to the credit of the assessee, and the assessee is therefore entitled to credit under sections 199 and 205 of the Act; denial of such credit results in retention of tax without any corresponding liability. She further submitted that the AO and the Ld.CIT(A) mechanically restricted the credit by comparing Form 26AS with the receipts offered, without examining the nature of the underlying transaction, and that the Ld.CIT(A) passed a non-speaking order. As regards the MOU, she submitted that its non-production before the Ld.CIT(A) was inadvertent and not deliberate, and prayed that it be admitted in the interest of justice. 14. We have heard the rival submissions, perused the orders of the authorities below and carefully examined the material available on record, including the paper book filed by the assessee. The short issue that arises for our consideration is whether the assessee is entitled to credit for the tax deducted at source by ACSL, to the extent not allowed in the intimation u/s.143(1) of the Act (the shortfall being Rs.20,71,055/-), where the corresponding receipt on transfer of the intangible assets has not been offered to tax in the return of income on the plea that the transfer is covered by section 47(v) of the Act. 15. At the outset, we deal with the prayer of the assessee for admission of the MOU dated 01.01.2022 as additional evidence. Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963 ordinarily bars the parties from producing additional evidence before the Tribunal, but empowers the Tribunal, for reasons to be recorded, to allow a document to be produced where it requires the same to enable it to pass orders or for any other substantial cause. The Hon'ble Delhi High Court, in CIT v. Text Hundred India Pvt. Ltd. (ITA Nos.2077, 2061 and 2065/2010, order dated 14.01.2011, neutral citation 2011:DHC:228-DB), held that the Tribunal has a judicial discretion to admit additional evidence, which may be exercised on the application of a party to the appeal and is not confined to cases where the Tribunal itself calls for the document, provided the Tribunal is satisfied that the evidence has a material bearing on the issue and its admission is necessary for proper adjudication and to do substantial justice. The Court also observed that procedure should not choke justice because of an inadvertent omission by a party to lead evidence at the proper stage.

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16.

In the present case, the MOU is the very instrument under which the intangible assets and intangible assets under development are stated to have been transferred by the assessee to its holding company, and it has a direct bearing on whether the receipt on which tax was deducted is consideration for a transfer of capital assets covered by section 47(v) of the Act. The explanation offered for not having produced it before the Ld.CIT(A) is that the assessee, which then handled the matter itself, considered the details furnished to be sufficient, and that the present counsel identified its relevance on reviewing the record. Nothing has been brought to our notice to suggest that the omission was deliberate. Since the document is necessary for a proper determination of the issue and no prejudice would be caused to the Revenue as the matter is being restored to the AO for examination, we admit the MOU as additional evidence under Rule 29 of the Rules. 17. Section 199(1) of the Act provides that any deduction made in accordance with Chapter XVII-B and paid to the Central Government shall be treated as a payment of tax on behalf of the person from whose income the deduction was made, and section 205 of the Act provides that the assessee shall not be called upon to pay the tax himself to the extent tax has been deducted from his income. Rule 37BA(3)(i) of the Income-tax Rules, 1962 provides that credit for tax deducted at source and paid to the Central Government shall be given for the assessment year for which such income is assessable. Coordinate Benches of the Tribunal have, where the TDS credit claimed in the return differed from the credit granted on processing, restored the issue to the file of the AO for verification and grant of credit in accordance with section 199 read with Rule 37BA (see Abarna & Ananthan, ITA No.268/Bang/2022, order dated 14.07.2022, ITAT ‘A’ Bench, Bangalore), and have held that the point of time at which TDS credit is to be given is governed by Rule 37BA(3), i.e., the year in which the corresponding income is assessable (see Greatship (India) Ltd., ITA Nos.1292 & 1293/Mum/2022, order dated 14.10.2022, ITAT Mumbai). 18. The authorities below have restricted the credit to the TDS corresponding to the receipts of Rs.12,76,06,091/- offered to tax in the return of income, without examining the nature of the transaction on which the balance tax was deducted. That approach proceeds on the footing that the balance receipt is income which ought to have been offered to tax in this year. The case of the assessee is the converse: that the receipt

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is consideration for transfer of capital assets by a wholly owned subsidiary to its Indian holding company, which by virtue of section 47(v) of the Act is not a transfer for the purposes of section 45, and that no income therefore arises. We express no opinion on the merits of that plea at this stage. We only observe that if the plea of the assessee is ultimately accepted, the tax deducted and deposited on that receipt to the credit of the assessee would be tax paid in excess of the amount with which the assessee is properly chargeable, a situation in which the Act contemplates a refund u/s.237 of the Act; the mere non-inclusion of the receipt in the return of income cannot, by itself, be a ground to deny the credit. Conversely, the benefit of section 47(v) is available only if its conditions are satisfied, and if the receipt or any part of it (for example, amounts relating to post-transfer employee costs, completion work, client support and monthly consultancy services, which the MOU provides are to be charged separately by the assessee) is in the nature of income chargeable to tax in the hands of the assessee, such income would have to be brought to tax and credit for the corresponding TDS given in accordance with law. 19. These are matters requiring factual verification: the terms of the MOU and its Schedules, the share-holding of ACSL in the assessee throughout the previous year, the character of the assets transferred and their treatment in the books, the manner in which the consideration is made up, the reflection of the tax deducted in Form 26AS against the PAN of the assessee, and the reconciliation of the shortfall in credit with the receipts disclosed in the return. None of this has been examined by the authorities below. The AO declined to act in the rectification proceedings, which are confined to a mistake apparent from the record; but the Ld.CIT(A), who was seized of the appeal and was required to dispose of it on merits by a reasoned order, sustained the restriction on the ground that the credit is limited to the income offered in the return, and the nature of the underlying transaction does not appear to have been examined. In these circumstances, and having regard to the admission of the MOU as additional evidence, we are of the considered view that the matter requires fresh examination at the level of the AO. 20. We, therefore, set aside the order of the Ld.CIT(A) and restore the issue to the file of the jurisdictional AO with the following directions:-

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(a) The AO shall take the MOU dated 01.01.2022, together with its Schedules, and such other documents as the assessee may file, on record, and examine whether the transfer of the intangible assets and intangible assets under development to ACSL satisfies the conditions of section 47(v) of the Act, in particular that the whole of the share capital of the assessee was held by ACSL and that ACSL is an Indian company, that the assets transferred are capital assets, and the true nature of each component of the amount of Rs.2,84,69,340/-, including any component relating to separately chargeable services. (b) The AO shall verify from Form 26AS, AIS and the TDS records that tax of Rs.28,46,934/- was deducted by ACSL u/s.194J(b) of the Act, deposited to the account of the Central Government, and reflected against the PAN of the assessee, and shall reconcile the shortfall of Rs.20,71,055/- in the TDS credit and the receipts of Rs.12,76,06,091/- disclosed in the return with Form 26AS. (c) After such verification, the AO shall allow the credit for tax deducted at source in accordance with sections 199 and 205 of the Act read with Rule 37BA of the Income-tax Rules, 1962, including to the extent the corresponding receipt is held not to be chargeable to tax in the assessment year 2022-23 by reason of section 47(v) of the Act, while ensuring that the same TDS is not credited more than once, whether in this or any other year. (d) The AO shall recompute the consequential interest under the relevant provisions of the Act, including sections 234A, 234B and 234C, as applicable, and the resultant demand or refund. (e) The AO shall pass a speaking order in accordance with law after giving the assessee a reasonable opportunity of being heard. The assessee shall file all the documents and evidence on which it relies and co- operate in the proceedings without seeking unnecessary adjournments. 21. Accordingly, Ground Nos.1 and 11 being general in nature call for no separate adjudication; Ground Nos.2 to 8 are allowed for statistical purposes in terms of the

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above directions; Ground No.9, regarding Article 265 of the Constitution of India, is left open in view of the restoration of the matter; and Ground No.10, regarding interest, is consequential and shall be given effect to by the AO as directed above. We clarify that we have not expressed any opinion on the applicability of section 47(v) of the Act or on the taxability of the receipt, and all contentions of both parties are left open for consideration by the AO in accordance with law. 22. In the result, the appeal of the assessee is allowed for statistical purposes.

Order pronounced in the open court on 27th October, 2026 at Chennai.

Sd/- Sd/- (मनु कुमार गिरर) (एस. आर. रघुनाथा) (MANU KUMAR GIRI) (S. R. RAGHUNATHA) न्याययक सदस्य/Judicial Member लेखासदस्य/Accountant Member

चेन्नई/Chennai, दिन ांक/Dated, the 27th October, 2026 Devadas आदेश की प्रतिलिपि अग्रेपिि/Copy to: 1. अपीलाथी/Appellant 2. प्रत्यथी/Respondent 3.आयकर आयुक्त/CIT– Chennai/Coimbatore/Madurai/Salem 4. ववभागीय प्रनतननधि/DR 5. गार्ा फाईल/GF DEVADAS Digitally signed by DEVADAS GOPALANACHARY GOPALANACHARY Date: 2026.10.28 17:55:52 +05'30'

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