ABDUL RAHMAN ASAD ,RIYADH, SAUDI ARABIA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTL. TAX 1(1)(1), NEW DELHI
In the result, the appeal filed by the assessee is allowed
ITA 2433/DEL/2025[2022-23]Status: DisposedITAT Delhi12 Nov 2025AY 2022-23
Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.Abdul Rahman Asad, Vs. Dcit, House No.47, Behind Jain Mandi, Circle Int. Tax 1(1)(1), Mohalla Barihat, New Delhi. Bahraich – 271 801 (Uttar Pradesh). (Pan : Aofpa6981F) (Appellant) (Respondent) Assessee By : Shri Alok Vasant, Fca Ms. Poonam Ahuja, Advocate Revenue By : Shri Vikram Singh Sharma, Sr. Dr Date Of Hearing : 21.08.2025 Date Of Order : 12.11.2025 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals), Delhi - 42 [“Ld. Cit(A)”, For Short] Dated 03.03.2025 For The Assessment Year 2022-23. 2. Brief Facts Of The Case Are, The Assessee Is A Non-Resident & Filed The Original Return Of Income For Ay 2022-23 On 27.07.2022 Declaring Taxable Income Of Rs.4,86,560/- (Income From House Property Rs.4,64,444/-, Income From Other Sources Rs.32,115/- & Loss From Long
For Appellant: Shri Alok Vasant, FCAFor Respondent: Shri Vikram Singh Sharma, Sr. DR
Section 199
grossly erred in suggesting that the transaction ought to have been reflected in the ITR for AY 2023-24. Section 199(3) of the Act read with Rule 37BA(3)(i) mandates that credit of TDS shall be given for the assessment year for which such income is assessable. Consequently