RISE WORLDWIDE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 4(2)(1), MUMBAI

Erred in up not granting Rs. 11,10,863 2. Failed to reflecting in F of which we was offered 2. Briefly stated, f return of income u/s ‘the Act’) the Central TDS credit of asses Rs.2,68,18,119/- ma intimation order pa allowed was short by reproduced the ‘TDS was sent to the asse order u/s 143(1) of th and possible resoluti said mismatch report “ SL No. Particulars 1. Credit available in For 26AS but not given in th pholding the action of the CPC, Bangalore credit of tax deducted at source to the e 3. appreciate that the said TDS credit Form 26AS of AY 2016-17 or AY 2018-19 ere submitted before the CIT(A) and to tax. facts of the case are that while s 143(1) of the Income-tax Act, Processing Centre (CPC) restric ssee to Rs.2,52,37,076/- as a ade in the return of income assed u/s 143(1) of the Act y a sum of Rs.15,81,043/-. The mismatch report’ generated by essee for giving its comments b he Act. The CPC also provided d ion for the mismatch. The relev t ( Table –C)is reproduced as un Resolution rm he 1a) Invalid TAN entered in the return: Flag is mentioned as 'N' in the column No.7 of Unmatched TDS and TCS Claimed in the Ret invalid TAN is quoted by you and in such ca not be matched with the claims. You are re application for rectification online under sect the correct TAN under 3c(i) category mentione (1b) SAT/AT details are entered wrongly details entered in respect of Self Assessment payment is exactly the same as appearing in Please ensure the amount claimed in the Rise Worldwide Ltd. 2 e thereby extent of is either 9, details d income e processing the , 1961 (in short cted the claim of against claim of . Thus, in the the TDS credit e Ld. CIT(A) has the CPC, which efore passing of detailed reasons vant part of the nder: In case Valid TAN f Table-B "Details of turn, it implies that ases the credit will equested to file an tion 154 by quoting ed below. y: Please check the t Tax/Advance Tax Form 26AS. e return is exactly

Before the Lear primary reason for th of certain TDS amo forward and claimed intimation order

Credit Not available Form 26AS rned CIT(A), the assessee cont he mismatch in TDS credit wa ounts in earlier years, which d in the assessment year unde matched to the amount in the payment challa the amounts. Please ensure the date is entered in DD/MM/ You are requested to file an application for under section 154 by quoting the correct CIN Date of deposit/ Challan Sequence number) 4c(i) category mentioned below. Ensure th details are exactly same as mentioned in Form (1c) "No data error in TAN/SAT/AT detail no data entry error (as mentioned in 1a and same matches with 26AS, you are requires t under 154 online under 4c(ii) category given b (1d) "No data error in particulars ente schedule": Please ensure that claim for consistent with the claim made in schedule same matches with 26 AS. In case, you are correction in schedule Part B-TTI of the R rectification under section154 under 4c(ii) c below. in (2a) Mismatch of TDS/TCS amounts claim Form 25AS: As the credit not appearing in take up the matter of mismatch in the TD Deductor / Collector so that corrective actio the Deductor / Collector. After the correctio corrected statement filed by your deductor th in 26AS. You can apply for online rectification to get the benefit of unmatched credits un given below. (2b) Mismatch of SAT/AT: In case of mis please follow up with the back where paymen Juri ictional Assessing Officer. After the cor the corrected statement filed by your Ban Assessing Officer, the credit will appear in 26 for online rectification under section 154 to unmatched credits under 4c(ii) category giv that all the above details are exactly sam Form 26AS. For further information/guidance on Challan logon to www.incometaxindia.gov.in - Correction Mechanism. Rise Worldwide Ltd. 3 ” tended that the s the non-claim h were brought r consideration, an. Do not round off /YYYY format. rectification online details (BSR code/ and amount under hat all the above m 26AS. ls: In case, there is 1b above) and the to file a rectification below. ered in TDS/TCS the TDS/TCS are Part B-TTI and the e required to make Return, file online category mentioned med compared to n 26AS, you should DS/TCS, with your n can be taken by on is done and the e credit will appear n under section 154 der 4c(iii) category match of SAT/AT, nt was made or the rrection is done and nk / Juri ictional 6AS. You can apply o get the benefit of ven below. Ensure e as mentioned in n correction - please Select Challan since the correspond earlier years but wa way of illustration, th 62,975/–, which had earlier year in the r mismatch in the im that, pursuant to a the corresponding pa of TDS or the write forgone TDS credit of Rs. 15,81,043/– a Accordingly, the asse the balance amount o 3.1 The Learned CIT primarily on the grou instance of misma corresponding TDS section 199 read with 4. We have heard t available on record. intimation under s 15,81,043/- in respe Learned CIT(A), the a submitting that the ding income had not been offer as offered in the relevant asses he assessee highlighted that an d been shown as TDS brought fo return of income, nevertheless mpugned intimation. It was fur reconciliation of the updated F arty accounts — owing to either e-off of balances — the asses f Rs. 6,80,180/– out of the tota as reflected in the impugn essee restricted its claim and s of Rs. 9,00,863/–. T(A), however, dismissed the as und that the assessee had not atch between the income of claim, as mandated under th h rule 37BA of the Income-tax R the rival submissions and perus The Centralized Processing Cen section 143(1) granted short ect of tax deducted at source (T assessee restricted its claim to balance amount had either b Rise Worldwide Ltd. 4 ed to tax in the ssment year. By n amount of Rs. orward from the appeared as a rther submitted Form 26AS with r the realization ssee voluntarily al short credit of ned intimation. sought credit for ssessee’s appeal reconciled each ffered and the he provisions of Rules, 1962. sed the material ntre (CPC) in its credit of Rs. TDS). Before the Rs. 9,00,863/-, been realized or written off and, hen grounds raised befor of Rs. 11,10,863/-. 4.1 The primary re assessee, is that the across multiple asse Rules, 1962 provides tax has been dedu Government, and the credit for such tax s proportion in which t 4.2 In such a case, the income offered consideration, along 26AS of earlier year earlier years. It is a verify such details including the TDS al to the current asse involves verification the assessee’s cla unnecessary multip circumstances of the order of the Learned nce, was not being pursued. H re us, the assessee has now sou eason for the mismatch, as ex e TDS credit claimed relates to essment years. Rule 37BA of s for such a situation. It stipul ucted at source and paid t e income is assessable over more shall be allowed across the yea the income is assessable. , the assessee is required to fu d to tax in the assessmen with the corresponding TDS re rs, credit for which was not cl also incumbent upon the Asse and examine each instance lready claimed and the portion essment year. Thus, the disp of facts by the Assessing Offic aim without proper verifica plicity of proceedings. In t e case, we deem it appropriate CIT(A) and restore the matter t Rise Worldwide Ltd. 5 However, in the ught TDS credit xplained by the o income spread the Income-tax lates that where to the Central e than one year, ars in the same urnish details of nt year under eflected in Form laimed in those ssing Officer to e of mismatch, carried forward pute essentially cer. Rejection of ation leads to the facts and to set aside the to the file of the Assessing Officer for Assessing Officer sha section 199 read wit TDS, if found eligible afforded a reasonable physical mode of h procedures. We orde allowed for statistical 5. In the result, statistical purposes. Order pronoun 1963 by way of plac (RAHUL CHA JUDICIAL M Mumbai; Dated: 29/05/2025 Rahul Sharma, Sr. P.S.