“credit for TDS”

TDS / TCSSection 199Section 199603 judgments

The decision most relied on for credit for TDS is Dy. CIT v. Rohini Builders (127 Taxmann 523), cited in 162 judgments on BharatTax.

Leading authorities on credit for TDS

Dy. CIT v. Rohini Builders

127 Taxmann 523 · 2003 · High Court

162

citing judgments

An assessee is required to prove the identity, creditworthiness, and genuineness of a cash credit in their books of accounts, such as an unsecured loan, but is generally not required to prove the source of the source for such credits. Additions under Section 68 are deleted if sufficient proof of creditors, repayment, and TDS on interest is provided.

Trib.), and Noida Commercial Co-op. Bank Ltd. v. ITO(TDS)

64 Taxmann.com 158 · 2015 · Reported

citing judgments

A multi-state cooperative bank is obligated to deduct tax at source on interest paid or credited on fixed deposits placed by cooperative societies, as per Section 194A(1) read with Section 194A(3) of the Act, unless an exemption applies.

CIT v. JDS Apparels (P.) Ltd.

370 ITR 454 · 2015 · High Court

citing judgments

Payments to banks for credit card transaction processing are considered bank charges or fees for services rendered, not commission or brokerage, and therefore are not subject to TDS under Section 194H of the Income Tax Act.

CIT v. Bhooratnam & Co.

357 ITR 396 · 2013 · High Court

citing judgments

An assessee is entitled to credit for TDS even if the certificate is issued in the name of a joint venture or related party, provided the income to which the TDS relates is offered by the assessee. This principle emphasizes looking at the substance of the transaction over strict adherence to the name on the TDS certificate.

Escorts Ltd. v. DCIT

15 SOT 368 · 2007 · ITAT

citing judgments

An assessee is entitled to credit for Tax Deducted at Source (TDS) even if the income in respect of which TDS was deducted is not disclosed in the return. The Income-tax Department cannot deny TDS credit solely on the grounds that the income was not offered to tax.

Yashpal Sahni v. ACIT

293 ITR 539 · 2007 · High Court

citing judgments

Once tax has been deducted at source (TDS), the bar of section 205 applies, preventing the deductee from being asked to pay the tax again, even if the deductor fails to deposit the tax or issue TDS certificates.

Supreme Renewable Energy Ltd. v. ITO

3 ITR (Trib) 339 · 2010 · ITAT

citing judgments

Once Tax Deducted at Source (TDS) is deducted and paid to the Central Government, credit for such tax must be given to the assessee, irrespective of the assessment year to which it relates. This principle applies even to amended provisions of Section 199(1) of the Income Tax Act, 1961.

PCIT v. Shree Aradhana Urban Co-operative Credit Society Ltd.

172 Taxmann.com 537 · 2025 · High Court

citing judgments

A co-operative society is primarily a co-operative society, and therefore, it is not required to deduct tax at source on interest payments made on time deposits to other co-operative societies, by virtue of Section 194A(3)(v).

Judgments citing credit for TDS

Deepak Munilalji Hirani, Mumbai vs. Central Circle 2, Thane

In the result, the appeal of the assessee is allowed

ITA 2036/PUN/2024[2023-24]Status: DisposedITAT Pune12 Nov 2024AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2036/Pun/2024 "नधा"रण वष" / Assessment Year : 2023-24

For Appellant: NoneFor Respondent: Shri Arvind Desai

Section 143(1)Section 143(1)(a)Section 154Section 250Section 57(1)

accepted while dealing with the appeal against the rectification order u/s.154 of the Act. Accordingly, the action of the CPC in restricting the credit for TDS by applying the rule 37BA of the I.T.Rules is upheld. The ground no.1 raised by the appellant is DISMISSED.” 5. On going through

Lec-Tpl Ujv, Mumbai vs. Income Tax Officer Ward 41(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3748/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Nov 2024AY 2021-22

For Appellant: Shri Malay KalavadiaFor Respondent: Shri Manoj Kumar Sinha (SR. DR.)

Section 143(1)Section 250

assessment year [A.Y.] 2021- 22. 2. The grounds of appeal taken by the assessee are as under: Ground No. 1 : Grant of short credit of TDS to the extent of Rs. 22,63,023/- Page |2 ITA No. 3748/Mum/2024 A.Y, 2021-22 LEC-TPL UJV “On the facts and circumstances ... Deducted at Source (“TDS”) to the Appellant i.e., TDS claimed in return of income (ITR) at Rs. 29,98,646/- whereas the credit of TDS granted in the order of the Ld. CIT (A) is Rs. 7,35,623/- resulting in short grant of TDS to the extent

Suzlon Energy Ltd., Ahmedabad vs. The ACIT(OSD) Circle-8, Ahmedabad

In the result the appeal filed by the Assessee in ITA No

ITA 1621/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

claimed is not defined under the DTAA. Hence, one needs to refer and rely upon domestic provisions. Under domestic provisions, credit for TDS has been provided for under Chapter XVII of the Act. Section 199 deals with "Credit for tax deducted". At this stage, it is essential to have ... available on record and gone through the orders of the authorities below. The brief facts of the case are that the assessee claimed credit for TDS of Rs 1,73,52,062/- for the AV 2006-07 and Rs. 2,25,09,037 in AV 2007-08 which

The DCIT, Circle-4(1)(1), Ahmedabad vs. Suzlon Energy Ltd., Ahmedabad

In the result the appeal filed by the Assessee in ITA No

ITA 1517/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

Deutsche India Pvt. Ltd.(Earlier Known As 'Dboi Global Services Pvt. Ltd.), Mumbai vs. ACIT-1(3)(1), Mumbai

In the result, the appeal by the assessee is partly allowed for 16

ITA 2522/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Oct 2024AY 2017-18

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. MistriFor Respondent: Ms. Neena Jeph (CIT-DR)

Section 143(3)Section 144C(13)Section 144C(5)Section 92CSection 92D

part of the CSR expenditure of Rs.3,69,04,854 debited to the profit and loss account. 3. The AO erred in granting credit for TDS of Rs.6,32,01,974 as against Rs.6,40,75,417 claimed by the Appellants in the modified return of income thereby granting short ... credit of TDS amounting to Rs. 8,73,443. The appellants pray that AO be directed to grant balance TDS credit of Rs.8,73,443. 4. The AO erred in charging interest of Rs.1,26,28,36,544 under section 234B of the Act. The appellants pray that

Rapport Outdoor Advertising Private Limited, Mumbai vs. DCIT-3(3)(1), Mumbai

ITA 949/MUM/2024[2014-15]Status: DisposedITAT Mumbai25 Oct 2024AY 2014-15

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Ajit JainFor Respondent: Smt. Mahita Nair, Sr.DR

Section 115Section 142(1)Section 143(2)Section 143(3)Section 250

were issued and served on the assessee. During the assessment proceedings, it was observed that the assessee has claimed credit for TDS amounting to INR 1,34,10,835. Accordingly, the assessee was asked to furnish the reconciliation of income vis-à-vis the income as per Form 26AS

Jyothy Industries, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(2)(1), Bangalore

ITA 1777/BANG/2024[2016-17]Status: DisposedITAT Bangalore24 Oct 2024AY 2016-17

Bench: Shri George George K

For Appellant: Shri. B. S. Balachandran, AdvocateFor Respondent: Shri. Ganesh R Gale, Standing Counsel for Department

Section 143(3)Section 198Section 199Section 250

facts of the case and is not maintainable in law. 2. The learned CIT(A) erred in upholding the denial for credit of TDS to the appellant erroneously, relying on the proviso to Rule 37BA of ITR 1962 on the premise that the appellant has not shown to have filed ... erred in not appreciating the legal position that the proviso to rule 37BA cannot be so interpreted as to deny the credit for TDS as required by the provision of section 198/199 as held by the Hon'ble appellate tribunal, Pune, in the case of Anil Ratanlal Bohara VS ACIT

Bhaskar Danve Patil, Jalna vs. Assistant Commissioner of Income Tax, Circle, Jalna

In the result, the appeal of the assessee is partly allowed for statistical purposes with the directions given above

ITA 285/PUN/2024[2016-17]Status: DisposedITAT Pune14 Oct 2024AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Mrs. M.N. KulkarniFor Respondent: Shri Ramnath P. Murkunde

Section 143(1)Section 143(2)Section 234B

respect of disallowances made by Assessing Officer. Appellant prays for accepting Returned Income. 4. Lower Authorities have erred in not granting full Credit for TDS as claimed. 2 ITA No.285/PUN/2024, AY 2016-17 Appellant prays for direction for granting full credit of TDS as per updated 26AS. 5. Lower Authorities ... directed to modify the assessment order accordingly. 11. Ground No. 4 relates to denial of credit for TDS. After hearing the parties, we direct the Ld. AO to verify the claim of the assessee and allow the credit, if the claim on verification is found to be correct. We order

Testec Asia Limited, United Arab Emirates vs. The Deputy Director of Income Tax, Circle International Taxation, Vadodara

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

ITA 44/AHD/2024[2022-23]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2022-23

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.44/Ahd/2024 िनधा"रण वष" /Assessment Year : 2022-23 Testec Asia Limited The Dy.Director Of Income Tax बनाम/ United Arab Emirates Circle, International Taxation V/S. P.O. Box No.16799, Dubai, Vadodara- 390 007 United Arab Emirates – 999999 (Or) Villa 11, Street 5, Medows 1, Emirates Hill, United Arab Emirates – Not Listed 999999 "थायी लेखा सं./Pan: Aajct 4035 A (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Virat Bhavsar, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 23/09/2024 घोषणा की तारीख /Date Of Pronouncement: 30/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

For Appellant: Shri Virat Bhavsar, ARFor Respondent: Shri Rignesh Das, Sr.DR

Section 139(1)Section 139(5)Section 143(1)Section 205Section 250

held, and not directly in the name of the assessee. Since the assessee was only the beneficial owner, the CIT(A) held that credit for TDS could only be allowed if the assessee complied with the procedural requirements, including filing declarations with the deductor and ensuring that the deductor reports ... appreciating the facts of the case in proper perspective. 5. The learned CIT(A) erred in law and in fact in denying the credit of TDS of Rs.57,28,565/- despite of the fact that the Appellant had demonstrated that in substance the requirements of the provisions of Rule 37BA

Deloitte Haskins and Sells, Kolkata vs. Income Tax Officer- Ward 22, (2), Kolkata

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

ITA 598/KOL/2024[2022-23]Status: DisposedITAT Kolkata27 Sept 2024AY 2022-23

Bench: Dr. Manish Borad & Shri Sonjoy Sarmai.T.A. No.598/Kol/2024 Assessment Year: 2022-23

Section 143(1)Section 250

against TAN SHLM01225A is paid by the appellant. 3. The learned CIT(A) erred in not directing the learned AO to allow credit for TDS of Rs.4,80,000 claimed against TAN CALB19171F. 3.1. The learned CIT(A) erred in holding that CPC has accepted the claim of the appellant ... intimation issued under section 143(1) of the Act. The learned CIT(A) ought to have appreciated that CPC has not allowed credit for TDS of Rs.4,80,000. 3.2. The learned CIT(A) ought to have directed the AO to allow TDS credit

Culver Max Entertinment Private Limited (Formerly Known As Sony Pictures Network India Private Limited Erstwhile Multi Screen Media Private Limited, Mumbai vs. The Commissioner of Income Tax-Circle 16(9), Mumbai

In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for In the result, the appeal filed by the assessee is allowed for statisti...

ITA 3360/MUM/2024[2018-19]Status: DisposedITAT Mumbai27 Sept 2024AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2018-19 Culver Max Entertainment Pvt. Ltd., The Cit(A), Nfac, The Asst. Cit, (Formerly Known As Sony Pictures Circle 16(9), Room 439, 4Th Floor, Vs. Networks India Pvt. Ltd.), Aayakar Bhavan, Maharishi Karve Interface Building 7, 4Th Floor, Off Road, Malad Link Road, Malad (W), Mumbai-400020. Mumbai-400064 Pan No. Aabcs 1728 D Appellant Respondent

For Appellant: Mr. Nitesh Joshi &For Respondent: 22/08/2024

Section 37Section 40Section 90

facts and circumstances of the case and in law, the learned AO erred in not granting credit erred in not granting credit for TDS to the extent of Rs. 124,45,44,224 claimed in the ROl. for TDS to the extent of Rs. 124,45,44,224 claimed ... facts and circumstances of the case and in law, the leamed AO erred in not granting cred erred in not granting credit of TDS of Rs. 49,28,303 claimed additionally 49,28,303 claimed additionally before the learned AO during the course before the learned AO during the course

DCIT, Central Circle - 7(1), Mumbai vs. Rare Enterprises, Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 1442/MUM/2024[2018-19]Status: HeardITAT Mumbai27 Sept 2024AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Girish Agrawal

Section 143(3)

deletion of Rs.3.6 Crores added by the ld. Assessing Officer in respect of interest accrued and receivable by the assessee and credit for TDS thereon amounting to Rs.36 lakhs. 4. The Assessee had advanced Rs.30 Crore to M/s. DHARTI DREDGING & INFRASTRUCTURE LTD (Dharti) as under: Date Particulars Amt.in

Alliance Medical Equipments Pvt. Ltd., Kolkata vs. I.T.O., Ward - 12(2), Kolkata

In the result, appeal of the assessee isdismissed as withdrawn

ITA 1725/KOL/2024[2020-2021]Status: DisposedITAT Kolkata26 Sept 2024AY 2020-2021

Bench: Shri Sonjoy Sarma (Judicial Member)

Section 143(3)Section 144BSection 244A

been offered to tax during A.Y.: 2020-2021. (b) For that the Ld. CIT(A) erred in directing the A.O. to grant credit for TDS only to the extent of TDS done on the amount of commission offered to tax for A.Y.: 2020-2021. 2. For that on the facts

Donthemsetty Srisaila Mallikharjunarao, Eluru vs. Income Tax Officer, Ward-1, Eluru

In the result, appeal filed by the assessee is allowed for statistical purposes as indicated herein above

ITA 276/VIZ/2024[2023-24]Status: DisposedITAT Visakhapatnam25 Sept 2024AY 2023-24

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.276/Viz/2024 (िनधा"रण वष" / Assessment Year : 2023-24) Donthemsetty Srisaila Vs. The Income Tax Officer, Mallikharjunarao, Ward-1, Eluru. Eluru. Pan: Abmpd8453H (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Smt. A. Aruna, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 20/08/2024 घोषणा क" तारीख/Date Of : 25/09/2024 Pronouncement O R D E R

For Appellant: Smt. A. Aruna, ARFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 143(1)Section 143(3)Section 89

considered the submissions of the assessee and directed the Ld. AO to verify the total receipts shown in 26AS and ITR and give credit of TDS to the assessee if the corresponding income has been offered for taxation in his income tax return in the relevant year after verification. Thus ... also the law applicable to the facts of the case. 2. The Ld. CIT(A) ought to have held that the granting lesser credit for TDS is outside the scope of adjustments that can be made in the intimation

Shri Pawan Kumar Ruia., Kolkata vs. DCIT, Cir- 30, Kolkata.

In the result, the appeal is allowed

ITA 1197/KOL/2023[2014-15]Status: DisposedITAT Kolkata23 Sept 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.1197/Kol/2023 Assessment Year: 2014-15 Shri Pawan Kumar Ruia…..…….…....…………….......…....………....Appellant 5, Sunny Park, Kolkata – 700019. [Pan: Acnpr3823K] Vs. Dcit, Circle-30, Kolkata.......................................................…..…..... Respondent Appearances By: Shri Manoj Kataruka, Advocate, Appeared On Behalf Of The Appellant. Shri Sailen Samadder, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 30, 2024 Date Of Pronouncing The Order : September 23, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 11.09.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Sole Issue Involved In This Appeal Is Relating Non-Credits Of Tds Of Rs.95,80,949/- Out Of Total Tds Claim Of Rs.2,18,82,526/-. 3. The Brief Facts Of The Case Are That The Assessee Is An Individual & Derived Salary Income & Income From Other Sources. The Assessee Filed Its Return Of Income On 17.07.2014 Declaring A Total Income Of Rs.6,52,52,390/-. The Assessment Was Completed U/S 143(3) Vide Order Dated 17.12.2016 At A Total Income Of Rs.6,86,66,708/-. The Assessee

Section 143(3)Section 250

Income Tax Act (hereinafter referred to as the ‘Act’). 2. The sole issue involved in this appeal is relating non-credits of TDS of Rs.95,80,949/- out of total TDS claim of Rs.2,18,82,526/-. 3. The brief facts of the case are that the assessee ... Pawan Kumar Ruia in this appeal has not disputed the addition of Rs.49,776/- made by the Assessing Officer. The assessee had claimed credit of TDS of Rs.2,18,82,526/- in the return of income. The Assessing Officer, however, has allowed the credit of TDS of Rs.1

Immaculate Heart of Mary Hospital, Kottayam vs. ACIT Exemption Circle, Trivandrum

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

ITA 342/COCH/2023[2014-15]Status: DisposedITAT Cochin20 Sept 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2014-15

For Appellant: Shri Prasanth Srinivas, CAFor Respondent: Smt. Girly Albert, Senior DR

Section 11Section 12ASection 143(3)Section 250

against the said order, the assessee filed an appeal before the Ld.CIT(A) and contended that the AO ought to have given credit for TDS amount and refunded the same which was duly shown by the assessee in their return and which was also reflected in form 26AS. The Ld.CIT ... interests of the appellant.; 2. From the facts, it is clear that the AO and CIT (A) erred by not allowing credit for TDS and refund amounting Rs. 1,22,133/-, which the appellant is rightfully entitled to. The AO / CIT (A) should have granted credit for TDS and consequent

Sharad Kumar, Chennai vs. Deputy Commissioner of Income Tax, Media Circle

In the result, appeal filed by the assessee is allowed

ITA 1381/CHNY/2024[2010-2011]Status: DisposedITAT Chennai18 Sept 2024AY 2010-2011

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1381/Chny/2024 िनधा"रण वष"/Assessment Year: 2010-11 V. Mr. Sharad Kumar, The Dcit, New No.6, Old No.7, Media Circle-1, Nawab Habibullah Avenue, Chennai. 3Rd Street, Chennai-6. [Pan: Aasps 2554 F] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. D. Anand, AdvFor Respondent: Ms. T.M.Suganthamala

Section 2(24)(iv)

that M/s. KTVPL had given an additional amount of Rs.94,64,375/- to the assessee and also noted that the assessee had claimed credit of TDS amounting to Rs.87,16,742/- in the AY 2009-10 and also claimed credit of TDS of Rs.7 ... Kalaignar TV Pvt. Ltd. and the above benefit had been obtained by him from the above company. On one hand, the appellant claimed credit for TDS made by the company and on the other hand, he received the extra amount from the company in the guise of interest payment

The Executor to the Estate of Sukhendu Prasad Choudhury, Kolkata vs. A.C.I.T., Circle - 29, Kolkata

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

ITA 1278/KOL/2024[2022-2023]Status: DisposedITAT Kolkata12 Sept 2024AY 2022-2023

Bench: Sri Sonjoy Sarma & Sri Sanjay Awasthi

Section 143(1)

after having carried out the verification and upon his satisfaction regarding the claim of the appellant is directed to allow the credit of TDS amounting to Rs. 71,583/- to the appellant. During verification process, proper opportunities of being heard are to be given to the appellant ... after having carried out the verification and upon his satisfaction regarding the claim of the appellant is directed to allow the credit of TDS amounting to Rs.71,583/- to the appellant, but it should be fully allowed in accordance with law because the Executor assessee has shown the income

V.K. Manimaran, Chennai vs. DCIT, Media Circle -1, Chennai

In the result, the appeal of the assessee is partly allowed in above terms

ITA 474/CHNY/2024[2009-10]Status: DisposedITAT Chennai06 Sept 2024AY 2009-10

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.474/Chny/2024 (िनधा"रणवष" / Assessment Year: 2009-2010 ) V.K.Manimaran, Vs. The Deputy Commissioner Of No.63/4, Meenakshi Apartments, Income Tax, Muthuvel Street, Media Circle I, Kodambakkam, Chennai. Chennai 600 024. [Pan: Agkpm 0164F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. C. Subramanian, C.A., ""यथ" क" ओर से /Respondent By : Shri. Ar.V. Sreenivasan, Irs, Addl Cit सुनवाई क" तार"ख/Date Of Hearing : 09.07.2024 घोषणा क" तार"ख /Date Of Pronouncement : 06.09.2024 आदेश / O R D E R Per Manu Kumar Giri ()

For Appellant: Shri. C. Subramanian, C.AFor Respondent: Shri. AR.V. Sreenivasan, IRS, AddL CIT

Section 143(2)Section 143(3)Section 194Section 40

payment to Mr. Muthukrishnan : Rs.7,00,000/- Mr. Ganapathy : Rs.5,00,000/- 6. Disallowance u/s.40(a)(ia) amounting to Rs.4,05,500/-. 7. Credit for TDS amounting to Rs.8,03,369/-.’’ 3. Facts relating to assessment u/s.143(3) of the Act are as under:- The Assessee is running the business ... TDS and whether paid before due date and if found true by the AO, he will allow the same. V. The issue of credit of TDS of Rs.8,03,369/- and Interest u/s 234B are consequential in nature and direct the AO to recomputed the income a fresh after considering

Shell Information Technologies International Bv, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation)-4(2)(1), Mumba

In the result, the assessee’s appeal is partly allowed

ITA 4711/MUM/2023[2021-22]Status: DisposedITAT Mumbai06 Sept 2024AY 2021-22

Bench: Ms. Kavitha Rajagopal & Smt. Renu Jauhrishell Information V/S. Dcit (International Tax)- Technology International बनाम 4(2)(1), Bv 17Th Floor, Room No. 1708, C/O. Bsr & Co. Llp, Air India Building, 2Nd Floor, Lodha Excelus, Nariman Point, Apollo Mills Compound, Mumbai-400021 N.M. Joshi Marg, Mahalakshmi, Mumbai-400011 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaics9091A Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Shri Madhur AgarwalFor Respondent: Smt. Shaileja Rai

Section 143(3)Section 144C(13)Section 144C(5)Section 153Section 2(24)Section 234ASection 234BSection 234C

without appreciating the fact that receipts towards IT support services are not for information concerning industrial, commercial or scientific experience; Short granting of credit for TDS 10. Erred in not granting the TDS credit of Rs. 1,03,96,003 without appreciating the facts and circumstance of the case. Interest