HARJAS LOGIC SYSTEMS PRIVATE LIMITED,NEW DELHI vs. DCIT, CIRCLE 10(1), CR BUILDING
What did the Tribunal hold?
The Tribunal noted that the lower authorities had denied the TDS credit for want of necessary details. The Tribunal found that the issue required fresh factual verification and reconciliation.
What were the facts?
The assessee's appeal for AY 2024-25 arose against an order that disallowed TDS credit for Rs. 18,73,263. The assessee claimed this credit based on TDS deducted by its tenants on rental income.
What were the issues?
Whether the assessee is entitled to claim TDS credit on rental income where TDS was deducted by the tenant. Whether fresh factual verification is required for adjudication of TDS credit claims.
Which sections of the Income-tax Act were involved?
Section 205,Section 203,Section 200,Section 143(1),Section 254(1)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘B’, NEW DELHI
Before: Sh. Satbeer Singh Godara & Sh. Manish Agarwal
Asstt. Year: 2024-25 Harjas Logic Systems Pvt. Ltd., Vs DCIT, L-8, Beekay House, Green Park Extn. Circle-10(1), New Delhi-110016 New Delhi-110001 (APPELLANT) (RESPONDENT) PAN No. AABCH5125K Assessee by : Sh. Akshat Aggarwal, CA Revenue by : Sh. Rajesh Kumar Dhanesta, Sr. DR Date of Hearing: 16.10.2025 Date of Pronouncement: 16.10.2025 ORDER
Per Satbeer Singh Godara, Judicial Member:
This assessee’s appeal for Assessment Year 2024-25, arises against the Addl./JCIT(A)-4, Mumbai’s DIN & order No. ITBA/APL/S/250/2024-25/1073851946(1) dated 28.02.2025, in proceedings u/s 143(1) of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
The assessee pleads the following substantive grounds in the instant appeal: “1. The Ld. CIT(A) has erred in law and on facts while passing the order not allowing the TDS credit of Rs. 18,73,263 is bad in law and on facts in view of the provision of section 205, 203 and 200 and raising a Harjas Logic Systems Pvt. Ltd. demand from the appellant inspite of the fact that TDS has been duly deducted by the tenant is not justified. 2. The appellant craves for leave to alter, amend, waive, modify, vary, delete and/or add to the aforesaid grounds of appeal
and prays for appropriate relief on the basis of the above said ground and/or such other relief as may be allowed to be urged by leave.”
4. It next transpires during the course of hearing with the able assistance coming from both the parties that the assessee’s sole substantive ground herein seeks to claim TDS credit qua it’s tenants rental income/receipt paid after due deduction thereof. Both the learned lower authorities have admittedly denied the same for want of necessary details.
5. That being the case, we are of the considered view that the instant sole issue of TDS credit more requires afresh factual verification in reconciliation then a substantive adjudication in section 254(1) second appellate proceedings before the tribunal. We accordingly deem it appropriate to restore the assessee’s above sole substantive ground back to the learned assessing authority for it’s afresh appropriate adjudication in very terms therefore.
All other issues between the parties are kept open at this stage.
More judgments on Section 205
- Hanoze Harish Thakkar, Mumbai vs Income Tax Officer Ward 19(1)(5), MumbaiITA 9314/MUM/2025[2014-15]Status: Disposed25 Sept 2026AY 2014-15
- Amitava Datta, Kolkata vs I.T.O., Ward - 62(1), KolkataITA 1674/KOL/2026[2022-2023]Status: Disposed14 Sept 2026AY 2022-2023
- M. Visvesvaraya Industrial Research and… vs Commissioner of Income-Tax (Appeals)…ITA 4343/MUM/2026[2020-21]Status: Disposed9 Sept 2026AY 2020-21
- Sheth Fincap Services Private Limited… vs The Income-Tax Officer, DCIT 1(3)(1), MumbaiITA 4304/MUM/2026[2025-26]Status: Disposed7 Sept 2026AY 2025-26
- Anita Grover, Delhi vs Income Tax Officer, DelhiITA 4305/DEL/2026[2019-20]Status: Disposed31 Aug 2026AY 2019-20
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