“credit for TDS”

TDS / TCSSection 199Section 199603 judgments

JIVANBHAI SOMABHAI PATEL,UNJHA vs. THE ITO, WARD-1, PATAN

The appeal of the assessee is dismissed

ITA 2196/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Apr 2026AY 2022-23

Bench: Ms. Suchitra Kamble

For Appellant: Shri P F Jain, ARFor Respondent: Shri Umesh Kumar Agarwal, Sr. D.R

deductor, the same cannot be rectified by getting appropriate correction statement filed by the deductor. On the issue of granting of credit for TDS under Section 194Q, there is no infirmity in the action of the AO, CPC and therefore, no interference is needed, thus, there is no need

ESTATE OF PALLONJI SHAPOORJI MISTRY,MUMBAI vs. DEPUTY DIRECTOR OF INCOME TAX, BENGALURU

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 9185/MUM/2025[2024-25]Status: DisposedITAT Mumbai26 Mar 2026AY 2024-25

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Ninad PatadeFor Respondent: Shri Hemanshu Joshi, SR. DR

Section 143(1)Section 168Section 168(1)(b)Section 199Section 250

date of demise of Mr. Pallonji Shapoorji Mistry(PSM') the said income is offered to tax in hands of Appellant and accordingly, credit for TDS deducted in hands of PSM ought to have been allowed to Appellant viz. Estate of PSM. 1.2 The learned Commissioner of Income-tax (Appeal) erred ... Persons under section 168(1)(b) of the Act on 29/07/2024, declaring a total income of INR 78,07,290 and claimed credit of TDS of INR 3,56,931. The return filed by the assessee was processed vide intimation dated 22/10/2024 issued under section

THE BANK OF TOKYO MITSUBISHI UFJ,NEW DELHI vs. DCIT, CIRCLE- 3(1)(1), INTERNATIONAL TAXATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 7212/DEL/2017[2013-14]Status: DisposedITAT Delhi13 Mar 2026AY 2013-14

Section 143(2)Section 143(3)Section 144Section 44C

taxed on a gross basis, and there was no provision to allow such a deduction. The Tribunal also directed the AO to grant credit for TDS on the interest.", "result": "Partly Allowed", "sections": [ "143(3)", "144C(13)", "144C

HARI PARKASH,GANAUR SONIPAT vs. INCOME TAX OFFICER WARD -1, SONIPAT

In the result, the appeal filed by the assessee is allowed

ITA 5432/DEL/2025[2022-23]Status: DisposedITAT Delhi11 Mar 2026AY 2022-23

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarhari Parkash, Income Tax Officer, Shop No.2, New Anaj Mandi, Ward-1, Sonipat, Ganaur Mandi, Ganaur, Vs. Haryana. Sonipat, Haryana-131101. [ Pan-Aampp5718N (Appellant) (Respondent) Assessee By Shri Samyak Jain, Ca & Shri Subodh Jain, Adv. Department By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 21.01.2026 Date Of Pronouncement 11.03.2026 O R D E R Per Vimal Kumar, Jm: The Appeal Filed By The Assessee Is Against Order Dated 04.07.2025 Of The Learned Addl./ Joint Commissioner Of Income Tax (Appeals)-2, Pune [Hereinafter Referred To As ‘The Ld. Cit(A)’] Passed U/S 250 Of The Income Tax Act, 1961, [Hereinafter Referred To As ‘The Act’] Arising Out Of Rectification Order U/S 154 Of The Act Dated 16.01.2025 Of Ld. Assessing Officer, Central Processing Centre (Cpc), Bangalore For Assessment Year 2022-23. 2. Brief Facts Of The Case Are That Assessee Had Filed Return Of Income On 02.09.2022 Declaring Total Income Of Rs.4,95,250/- & Claiming The Tds Credit Had Hari Parkash Vs. Ito

Section 154Section 250

contrary, Ld. CIT(A) vide order dated 21.02.2024 for AY 2023-24 had directed Ld. AO to give credit for TDS claim made by assessee considering the commission reported by the appellant Hari Parkash vs. ITO as the turnover and determine the refund accordingly. Copy of order dated

DHARTI FOUNDATION,SABARKANTHA vs. THE DY.DIT, CPC PRESENT JURIS. THE ITO, EXEMPTION, PALANPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2250/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad09 Mar 2026AY 2022-23

Bench: Ms Suchitra Kambleआयकर अपील सं./Ita No. 2250/Ahd/2025 िनधा"रण वष"/Asstt. Year: 2022-2023 Dharti Foundation, The Deputy Director Of बनामVs. B/H Kheti Bank, Income Tax, Cpc Chhapariya Char Rasta, Present Jurisdiction, Himatnagar-383001, The Income Tax Officer, Sabarkantha. (Exemption), Palanpur.

For Appellant: Shri Rushin Patel, ARFor Respondent: Smt. Mamta Singh, Sr. DR

Section 143(1)Section 154Section 194ASection 194CSection 199(2)

raised the following grounds of appeal: 1. The Ld.CIT(A) erred in law and facts of the case, in sustaining the disallowance of credit of TDS of Rs.3,07,993/- while processing the return u/s.143(1) as well as while rectifying the same u/s.154 2. The appellant craves leave ... Order dated 01.05.2023, wherein TDS credit of Rs.26.697/- only is allowed against the claimed TDS credit of Rs.3,34,690/-CPC allowed only credit of TDS of Rs.26,697/-. Subsequently, the assessee filed rectification on 01.05.2023 and in response, CPC passed rectification order u/s 154 dated 11.05.2023, allowing TDS credit

SIVASUNDAR SELVAKUMARI,CHENNAI vs. ITO, NCW-1(6), CHENNAI

In the result, the appeal of the assessee is allowed

ITA 3154/CHNY/2025[2016-17]Status: DisposedITAT Chennai04 Mar 2026AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. N. Balakrishnan, CIT

Section 139(4)Section 144BSection 147Section 194ISection 45

individual, filed her return of income on 09.03.2018 u/s.139(4) of the Act, declaring total income of Rs.5,86,740/- and claimed credit for TDS of Rs.20,00,000/- deducted u/s.194IA of the Act in respect of sale of immovable property. A vacant land at No.148, Okkiyam Thoraipakkam Village, Sozhinganallur ... wherein he sought for details regarding sale / purchase of property during the year, expenses in connection with the transfer and reason for taking credit of TDS and not offering capital gain income in return of income. The assessee filed her response on 24.01.2022 wherein she again clarified that the income

B.V.KAPADIA HUF,KOLKATA vs. D.C.I.T, CPC, BENGALURU

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2879/KOL/2025[201-22]Status: DisposedITAT Kolkata27 Feb 2026

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139Section 139(5)Section 143(1)Section 199Section 250

appellate proceedings, have been thoroughly perused and considered carefully. The appellant has challenged the action of the CPC for short-granting of credit towards TDS claimed in the ROI filed for A.Y. 2021- 22 stating that "As per the statement of fact the shares against which dividend has been received ... Addl/JCIT(A) and remit the matter back to the Ld. AO for grant of summary relief in respect of the credit for TDS relating to the dividend income as in the case of an HUF, the shares are held in ITA No.: 2879/KOL/2025 Assessment Year: 2021-22 B.V. Kapadia

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6030/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Feb 2026AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A

claiming relief u/s. 91 amounting to Rs. 29,19,641/-, net tax liability was determined at Rs. 12,65,943/- and after claiming credit for TDS amounting to Rs 12,65,943, final tax liability was determined at Nil. 4. The return was selected for limited scrutiny under Computer Assisted

BOBST BIELEFELD GMBH,GERMANY vs. THE ASSISTANT COMMISSIONER OF INCOME TAX INT TAX CIRCLE 1(3)(1), MUMBAI, MUMBAI

ITA 6029/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Feb 2026AY 2017-18

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadav

For Appellant: Shri Siddesh ChauguleFor Respondent: Shri Krishna Kumar, Sr.DR

Section 234Section 234ASection 270A

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

ITA 2195/BANG/2025[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22

Section 115BSection 143(1)Section 154Section 250Section 80G

return filed by\nthe assessee was processed by CPC and the CPC in the intimation order\nunder section 143(1) disallowed the credit of TDS of Rs. Rs. 2,59,879/-\non account of OLTAS Credit Mismatch. The rectification application filed\nby the assessee was also dismissed vide order passed ... required to be clubbed in the hands of the beneficiary.\nAccordingly, the appellant declared the said dividend income in her\nreturn and claimed credit of TDS amounting to Rs. 2,59,879/- deducted\non such income.\n13.2 The assessee submitted that while processing the return under\nsection

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

ITA 2194/BANG/2025[2019-2020]Status: DisposedITAT Bangalore24 Feb 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Balusamy N, JCIT

Section 115BSection 143(1)Section 154Section 250Section 80G

Page 11 of 16 the assessee was processed by CPC and the CPC in the intimation order under section 143(1) disallowed the credit of TDS of Rs. Rs. 2,59,879/- on account of OLTAS Credit Mismatch. The rectification application filed by the assessee was also dismissed vide order ... required to be clubbed in the hands of the beneficiary. Accordingly, the appellant declared the said dividend income in her return and claimed credit of TDS amounting to Rs. 2,59,879/- deducted on such income. 13.2 The assessee submitted that while processing the return under section

BHARAT KANTILAL DOSHI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 27(1), NAVI MUMBAI

In the result, all the appeals filed by the assessee are allowed for statistical purpose

ITA 7171/MUM/2025[2017-18]Status: DisposedITAT Mumbai23 Feb 2026AY 2017-18

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

offered\nthe corresponding income to tax, and TDS credit of Rs. 3.57,946/-should have been\ngranted as per Section 199.\n3. The credit for TDS of Rs. 3,97,946/- requires to be granted.\nVII. NON GRANT OF SA TAX CREDIT OF Rs. 9.870/-:\n1. The Learned

BHARAT KANTILAL DOSHI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 27(1), NAVI MUMBAI

In the result, all the appeals filed by the assessee are allowed for statistical purpose

ITA 7170/MUM/2025[2016-17]Status: DisposedITAT Mumbai23 Feb 2026AY 2016-17

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

BHARAT KANTILAL DOSHI,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 27(1), NAVI MUMBAI

In the result, all the appeals filed by the assessee are allowed for statistical purpose

ITA 7169/MUM/2025[2014-15]Status: DisposedITAT Mumbai23 Feb 2026AY 2014-15

Section 132(4)Section 147Section 148Section 154Section 234ASection 250Section 271(1)(c)Section 68

SANJAY BUDHRANI HUF,JABALPUR vs. DCIT, CPC, BENGLURU

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 198/JAB/2024[2019-20]Status: DisposedITAT Jabalpur13 Feb 2026AY 2019-20

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 143(1)

grossly erred, both on facts and in law, in confirming the action of the Id. DCIT, CPC, Bangalore in granting a credit of TDS claim to the tune of Rs.34,84,665/- only, as against the same claimed by the appellant at Rs.40,46,413/- in its return of income ... furnished for the relevant assessment year, thereby giving a short credit of TDS at Rs. 5,61,748/-. 3. That, the learned CIT(A) grossly erred, both on facts and in law, in confirming the action of the Id. DCIT, CPC, Bangalore in granting the credit for TDS claim only

ROHINI GAUTAMBHAI SHAH,AHMEDABAD vs. THE ITO, WARD - 1(3)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

ITA 1947/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad12 Feb 2026AY 2020-21

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 143(1)Section 154

order, the assesse is in appeal before us raising the following Grounds of Appeal: 1. The CIT(A) has erred in not granting credit for TDS of Rs.10,464/-and Rs.1,05,901/- aggregating to Rs.1,16,365/- under the contention that the TDS is deducted under ... husband as income of the Appellant, TDS thereon ought to have been allowed as a credit. 2. The CIT(A) has not granted credit of TDS on the ground that the Appellant has not filed income as legal heir of her late husband Shri Gautam B. Shah and hence

SHELL INTERNATIONAL PETROLEUM COMPANY LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-4(2)(1), MUMBAI

In the result, appeal of the assessee is allowed

ITA 1751/MUM/2025[2022-23]Status: DisposedITAT Mumbai11 Feb 2026AY 2022-23

Bench: Shri Amit Shukla & Shri Girish Agrawalshell International Petroleum Vs Deputy Commissioner Of Company Limited Income Tax (International C/O B S R & Co. Llp, 2Nd Floor, Taxation) 4(2)(1), Lodhaexcelus, Apollo Mills Mumbai Compound, N.M. Joshi Marg, Mahalakshmi, Mumbai 400011

For Appellant: Shri Madhur Agarwal and Shreyas Sardesai, AdvocatesFor Respondent: Shri Satya Pal Kumar, CIT DR

Section 144C(5)Section 2(24)Section 234BSection 9(1)(vi)

payments could not be considered as 'FTS' under the Act and under the Article 13(4) of India-UK DTAA Short granting of credit for TDS 10. Erred in not granting the TDS credit of Rs. 29,585 without appreciating the facts and circumstance of the case. Interest under section

DCIT-2(1)(1), MUMBAI, MUMBAI vs. INCRED FINANCIAL SERVICES LIMITED, MUMBAI

In the result, the appeal by the Revenue and the cross-objection by the assessee are dismissed

ITA 4703/MUM/2025[2021-22]Status: DisposedITAT Mumbai10 Feb 2026AY 2021-22

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhaildcit-2(1)(1), Mumbai Room No. 561, 5Th Floor, Aayakar Bhavan, Mumbai- 400021 ............... Appellant

For Appellant: Shri Madhur Agrawal a/wFor Respondent: Shri Virabhadra Mahajan, Sr. DR

Section 143(1)Section 154Section 199(1)Section 250

facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in directing the Assessing Officer to allow credit of TDS not reflected in Form 26AS merely on the basis of the assessee's claim and indemnity bond, without ensuring that whether ... filed the following details of short grant of TDS credit: – (Amounts in INR) SL Name of the party TAN of the party TDS credit claimed TDS credit Short TDS No. in ITR [A] granted as per credit [A-B] rectification order [B] 1 RA Associates MUMR17318A

BHARAT PAPER MART,MUMBAI vs. ASSISTATANT COMMISSIONER OF INCME TAX CIRCLE 17(1), MUMBAI

In the result, ground no.1 raised by the assessee is allowed

ITA 5594/MUM/2025[2013-14]Status: DisposedITAT Mumbai09 Feb 2026AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Bharat Paper Mart Assistant Commissioner Of 219, Podar Chambers, S.A. Income Tax Circle-17(1), Mumbai Brelvi Road, Fort, Mumbai Vs. Maharashtra 400001 (Pan: Aajfb0186H) (Appellant) (Respondent) Present For: Assessee : Dr. K. Shivaram. Sr. Advocate Revenue : Shri Leyaqat Ali Aafaqui, Sr. Dr Date Of Hearing : 12.11.2025 Date Of Pronouncement : 09.02.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of National Faceless Appeal Centre (Nfac), Delhi, Vide Order No. Itba/Nfac/S/250/2025-26/1078818110(1), Dated 23.07.2025, Passed Against The Assessment Order By Assistant Commissioner Of Income Tax- 17(1)(2), Mumbai, U/S. 143(3) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 04.03.2016 For Assessment Year 2013-14. 2 Bharat Paper Mart Ay 2013-14 2. Grounds Taken By Assessee Are Reproduced As Under: 1. The Learned National Faceless Appeal Centre (Nfac) Erred In Confirming Order Of Assessing Officer Disallowing Partner'S Remuneration Of Rs.31,30,490/- Paid To Working Partner Out Of Remuneration Of Rs.99,76,470/- Paid To Him Without Appreciating That Said Remuneration Was Paid In Accordance With The Provisions Of Section 40(B)(V) Of Income Tax Act 1961 & Hence The Disallowance Of Remuneration Of Rs. 31,30,490/- May Be Deleted. 2. The Learned Nfac Erred In Confirming Order Of Assessing Officer Taxing Commission Income Of Rs. 3,77,617/ On The Basis Of Form No. 26As Without Appreciating That Said Commission Income Was Not Taxable In A.Y. 2013-14 & Hence The Addition Of Rs. 3,77,617/- May Be Deleted. 3. The Appellant Craves Leave To Add, Amend, Alter Or Delete Any Of The Above Grounds Of Appeal.

For Appellant: Dr. K. Shivaram. Sr. AdvocateFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 143(3)Section 40

done. Fact of the matter is that, assessee offered the same to tax in the subsequent Assessment Year 2014-15 and claimed the credit for TDS also. Relevant documentary evidence in this regard are placed in the paper book. Considering these facts on record, verifiable from the documentary 6 Bharat

ACITLTU-2, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is partly allowed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 945/CHNY/2018[2009-10]Status: DisposedITAT Chennai05 Feb 2026AY 2009-10

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.895/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 Ashok Leyland Limited, Vs. The Deputy Commissioner Of 1, Sardar Patel Road, Guindy, Income Tax, Chennai 600 032. Company Circle – Ltu, Chennai. [Pan: Aaaca4651L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.945/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Assistant Commissioner Of Vs. Ashok Leyland Limited, Income Tax, 1, Sardar Patel Road, Guindy, Large Taxpayer Unit – 2, Chennai. Chennai 600 032. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Assessee By : Shri Vikram Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 05.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Dated 28.12.2017 Passed By The Ld.

For Appellant: Shri Vikram Vijayaraghavan, AdvocateFor Respondent: Shri AR V Sreenivasan, CIT

challenging the action of the ld. CIT(A) in not disposing the assessee’s submissions on the failure of the Assessing Officer grant credit for TDS Certificate. 46. We find no discussion whatsoever made by the Assessing Officer and the ld. CIT(A) in their respective orders. On perusal

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